PSPA Privacy Notice

We collect and process information, including personal information, to provide effective and efficient services and meet our regulatory objectives under the Public Sector Pensions Act 2011.

Any online, postal, email or phone communication you have with the PSPA are also classed as your personal information. These communications are retained in order to protect your interests and those of the schemes. Online, email and any postal communications are securely stored electronically and phone calls are recorded.

If the terms and conditions of your employment permit membership of a Scheme, your employer will automatically enrol you and tell the PSPA that you are a new member. 

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, its Orders, Regulations and Schemes and in particular in respect of the following Schemes:

• Isle of Man Government Unified Scheme 2011
• Judicial Pension Scheme 1992
• Judicial Pension Scheme 2004
• Police Pension Regulations 1991
• Police Pension Regulations 2010
• Police (Injury Benefit) Regulations 2010
• Public Sector Compensation Scheme 2013
• Public Sector Injury Benefit Scheme 2015
• Public Sector Interim Injury Benefits Scheme 
• Teachers Superannuation Order 2011
• The Superannuation (Manual Workers) (No.1) Scheme 1973

Your employer collects personal information from you both at the start of, during and at the end of your employment.

As part of your membership of a Scheme, your employer will share certain personal information with us, so that we can create and maintain a membership record for you.

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 or a
    
    
  • 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
  
  
• process and remit benefits related to your Scheme to any beneficiary, either appointed directly by you or not
  
  
• calculate and pay refunds of contributions and provide services to support the purchase of additional benefits
  
  
• calculate and pay a transfer of pension rights to and from other pension providers
  
  
• maintain facilities for Additional Voluntary Contributions
  
  
• detect, prevent and or prosecute financial and other crimes, for example money laundering and fraud
  
  
• provide data for or preparing budget estimates of income and expenditure and the monitoring of payments against estimates
  
  
• maintain accounts of income and expenditure
  
  
• provide data for analytical purposes to aid the planning of sustainability improvements to the Schemes
  
  
• provide accurate information to other parts of the Government and to the Schemes' actuaries for accounting and valuation purposes
  
  
• provide Cash Equivalent Transfer Values for divorce purposes and the implementation of Pension Sharing on Divorce Orders
  
  
• share with third parties contracted to provide interrelated services
  
  
• Establish, exercise or defend legal rights in connection with actual or prospective legal proceedings, including as necessary for the purpose of obtaining legal advice
  
  

The PSPA will only process your personal data if a lawful basis exists. Typically, the basis will be one of public interest on the basis that the PSPA is a Statutory Body with duties and responsibilities set out under the Public Sector Pensions Act 2011. Lawful basis might involve: 

• 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
  
  

When you join the Scheme, and regularly throughout your membership, your employer, their payroll provider or personnel services provider will provide us with personal information to help with the PSPA administration of your arrangements under the Scheme for example: 

The above personal information may also be used when investigating complaints made under the PSPA Complaints procedure and where scheme members utilise the Internal Dispute Resolution Procedure.

We may also process certain special categories of information for specific and limited purposes connected to the administration of pension schemes, for which the PSPA is responsible.  We will only process special categories of information where we have obtained your explicit consent or are otherwise lawfully permitted to do so. We may also process certain special categories of data as defined in the GDPR (Isle of Man) Order. This may include:

• Criminal proceedings, outcomes and sentences;
• Offences (including alleged offences)
• Data concerning health
  
  

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 those persons.

PSPA Board Members do not have access to personal data except where required for the direct execution of a statutory function.

We may share your information with other organisations: 

• with or between other Government Departments, Boards and Offices to the extent necessary in order to: pay your pension benefits, provide a Freedom of Information response via iCasework system, pension scheme related service or information you have requested, maintaining systems to support the prompt and accurate payment of sums due and for the confirmation of state related pension elements for contracting out purposes, such as Guaranteed Minimum Pension
  
  
• with internal or external auditors to comply with statutory obligations for the audit of the PSPA
  
  
• the police or law enforcement agencies where required to do so
  
  
• to prevent and detect fraud and mistake
  
  
• the courts, on production of a valid Court Order
  
  
• With the Isle of Man Pensions Ombudsman, the Tynwald Ombudsman or the PSPA's Lawyers in connection with Internal Dispute Resolution and/or other legal proceedings

The PSPA will share anonymised data wherever possible for the purposes of: 

• Scheme valuation, audit and accounting purposes

The PSPA shares your personal data with other companies, organisations or individuals when there is a legal requirement or regulatory function which requires us to do so.

We will share your data with companies and other organisations with whom we have entered into a contractual arrangement to provide interrelated services, such as the PSPA pension scheme administration systems.

The following companies are currently under contract to provide services to the PSPA:

• Provision of Actuarial and web based services – Hymans Robertson LLC and Barnett Waddingham LLP
  
  
• Provision of Audit Services – PwC Isle of Man LLP
  
  
• Provision of pension data base, administration software, support and maintenance services – Claybrook Computing Limited and Mantle Services Limited 46 New Board Street, London EC2M 1JH
  
  
• Provision of Archiving Services - Doxbond (I.O.M.) Limited
  
  
• Provision of Independent Medical Advice and Services for Ill Health and Injury Benefit Applications and Awards – BHSF Occupational Health Limited
  
  
• Provision of mailing services – Washington Direct Mail
  
  
• Provision of Pension Administration  services – Isle of Man Post Office (Omnidox)
  
  
• Provision of Administrator and Co Trustee services for IOMG Group AVC Schemes – MAC Financial Ltd
  
  
• Provision of Legal Services: Keystone Law, The Old Courthouse, Athol Street, Douglas IM1 1JD

The PSPA will not sell to, or share, your personal data with any company, organisation or persons who do not have a right to receive that data.

Your information will not generally be transferred outside the European Economic Area ('EEA'). If you make a request that we pay benefits or make a transfer of rights outside the EEA, we will only act with your prior permission and after the PSPA has determined appropriate safeguards consistent with the Data Protection Act 2018.

When you visit or use our website we may collect information sent to us by your computer, mobile phone, or other device. For example we may collect:

We will only keep your information for the minimum time necessary, with exceptions of when longer retention can be justified for statutory, regulatory, legal or security reasons, or for their historical value.

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

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 at:

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

Website: www.gov.im/pro
Telephone: +44 1624 693569

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

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

We will ensure that:

• Safeguards are in place to make sure personal information is kept and or transferred securely
  
  
• Only authorised staff are able to view your information
  
  
• We maintain security of the systems which hold personal information in line with ISO27001 standard
  
  
• PSPA compliance with the requirements of the PCI Security Standards Council
  
  
• We comply with the requirements of the Information Commissioner

We may share your information:

• With or between other Government Departments, Boards and Offices to provide a service or information you have requested, where there are arrangements in place to do so
  
  
• The courts on production of a valid court order

We will not sell to, or share, your personal information with other companies, organisations or individuals. The PSPA may share your personal information with other companies, organisations or individuals where there is a legal requirement to do so. Your personal information will not be disclosed to any third party without your prior consent or where required to do so by law.

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.

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 provide a means for you to have this information changed if it is not accurate.

Alternatively you can ask for the information we hold about you to be changed by making a request to the PSPA Data Protection Officer.

To remove your personal information

In certain circumstances you can ask for your information to be deleted. Please note that as part of the PSPA statutory functions some information may need to be retained.

You can request this by contacting the PSPA Data Protection Officer.

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 Data Protection Officer who will work with you to resolve any issues.

Email address: DPO@pspa.im

Telephone: +44 1624 687090

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

The Isle of Man’s Information Commissioner is the independent supervisory body responsible for upholding the public's information rights and promoting and enforcing compliance with the Island's information rights legislation.

You have the right to request the Information Commissioner to undertake an assessment as to whether the processing of your personal data has been carried out in accordance with the provisions of the Manx Data Protection Legislation. Further information regarding complaints to the ICO can be obtained through its website or by calling +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.

This Privacy Notice may be replaced, or more information added, when you send feedback, ask to use a service online or make a payment for a service through our website.

This privacy notice was last updated in January 2024.

Under the Data Protection Act 2018 you have a right of access to your personal data and to check the accuracy of that data by making a Subject Access Request.

A subject access request is made by filling in our Subject Access Request Form or contacting the Data Protection Officer (DPO) of the Department, Office or Board that collects the information.

We have a guidance sheet that gives you details on the Subject Access Request process.

To make a request of the DPO for the PSPA contact:

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

Email: DPO@pspa.im

Phone: +44 1624 687090

Subject access requests must be responded to promptly and in any event within a maximum of 1 month.

The Information Commissioner is the independent authority responsible for upholding the public's information rights and promoting and enforcing compliance with the Island's information rights legislation. Further information can be found on the Information Commissioner's website.

You have the right to request the Information Commissioner to undertake an assessment as to whether the processing of your personal data has been carried out in accordance with the provisions of the Data Protection Act 2018.

Isle of Man Freedom of Information Act 2015 ('FOIA')

The Freedom of Information Act 2015 (FOIA) gives Isle of Man residents a legally enforceable right to obtain access to documents held by a Public Authority. This is subject to certain exemptions and practical refusal reasons. You can find out more information on the FOIA including how to make a request to the PSPA.

You can also use this link to view previous requests and their responses.

The PSPA is the controller for the personal data that you provide when making a FOI request to the PSPA.

Legal basis for processing your information

We need your personal information (such as your name and contact details) to process and respond to you about your Freedom of Information request. In some cases, we may ask for proof of identification, and proof of residency, so that we can comply with the FOIA.

We must have a legal basis (a lawful reason) to process your personal data, which is submitted by you when you make a Freedom of Information request. The legal basis for processing your information when you make a request is that it is necessary for us to comply with the law (FOIA), or that it is necessary for us to perform a public task in the public interest. This is set out in Schedule to the Data Protection (Application of GDPR) Order 2018 – this legislation is sometimes called 'the Applied GDPR').

The legal basis for the PSPA processing your information when you make a request is:

Article 6(1)(c) Legal obligation of the Applied GDPR applies, that the processing is

• necessary for the Authority to comply with the law (not including contractual obligations)

Article 6(1)(e) Public Task of the Applied GDPR applies, that the processing is necessary for

• the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

Sharing information

FOI requests have to be submitted on a form prescribed by the Chief Executive Officer (Isle of Man Government) in order to be valid and accepted under FOIA. You can either submit a request using the form online or a paper version, which is available by contacting our Data Protection Officer (DPO) or by calling into the PSPA Offices. See below for the DPO contact information and PSPA address details. 

When the PSPA processes your FOI request, it uses the Online Services Portal on the Isle of Man Government website, a system called iCasework. The iCasework system is provided by a company called Civica UK Limited. This system stores information such as:

• Your name
  
  
• Your address
  
  
• Your telephone and email address
  
  
• Your company name, if you are requesting information on behalf of an organisation
  
  
• Your request – we do not recommend putting any personal information into your request, if you are not sure what to include in your request, please contact us on pspaicaseworkfoi@pspa.im for assistance
  
  
• If we have requested proof of residency from you

Civica UK Limited act as a Processor on behalf of the PSPA and all other Public Authorities. Civica UK Limited use the information held in the iCasework system for the purpose of providing a system to manage freedom of information requests and to transfer this information to the relevant public authority. The information you provide to Civica UK Limited will be kept secure and confidential. 

Access to your information is limited to authorised staff members within the PSPA. The Department of Home Affairs (DHA), through the Office of Cyber Security & Information Assurance (OCSIA), is in the process of being contracted, by the PSPA to manage the system administration on its behalf. The DHA through OCSIA will only access personal data held on the iCasework system when explicit written instructions are provided by the PSPA. You can read the DHA privacy notice on their website.

If you are unhappy with the response to your Freedom of Information request 

If you have been unhappy with a response the PSPA has provided and have exhausted the complaints procedure, you may complain about your request to the Information Commissioner’s Office. 

In this case, the PSPA will need to share information such as emails we have sent or received from you, with them so that they can investigate the complaint.

Storing your information

Your personal information will be held in iCasework for 12 months after the Public Authority has closed your request, or if you requested a review of your request, your personal information will be held in iCasework for 36 months after the Public Authority has closed your request. After this time, the request will remain on the iCasework system, but all your personal information you provided at the time of the request will be deleted.

Your rights

The Applied GDPR (data protection legislation) provides you as a data subject with some rights to be informed of the processing of your personal data, including the right to access that data and information about the purposes for processing.  This includes a right to correct (rectify) any information a public authority holds, or to restrict it in certain circumstances.

As the PSPA is processing your data in order to comply with its legal obligations, certain aspects of the data protection rights do not apply, including the right to have your data deleted (erasure), transferred to another provider, the right to object to the processing, and be informed about automated decision making.

When using the iCasework site or dealing with FOI requests, a Public Authority does not make automated decisions or profile your data.

Data Protection Officer

If you have any questions about how the PSPA processes your personal information, you can speak to our Data Protection Officer regarding your rights.

Email: DPO@pspa.im

Phone: +44 1624 687023 or +44 1624 685598

In writing to:

Data Protection Officer
PSPA
3rd Floor,
Prospect House,
27-29 Prospect Hill,
Douglas,
Isle of Man,
IM1 1ET

Details of rights under the data protection legislation can be found in the PSPA’s general Privacy Notice.

Additional information

Isle of Man Government Freedom of Information

Freedom of Information Act 2015 - legislation

Information Commissioner’s Office – Freedom of Information guidance page