The Trustees of the Christie Management Pension and Life Assurance Scheme commit to protecting your privacy. We will only use information about you in line with the Data Protection Act 1998/General Data Protection Regulation (DPA 1998/GDPR) and other relevant legislation and regulations. Our Privacy Notice is set out below; please read it with care as it describes how we will obtain, use and protect any personal information you provide to us. 

If you have any questions you should contact the Scheme Administrators or Trustees, contact details at the foot of this Notice. 

This Privacy Notice explains: 

• what information we may collect about you;
• how we keep your information safe;
• what we may use your information for;
• who we may share your information with;
• your rights regarding the personal information you provide to us.

The primary lawful bases on which we process the personal information you provide to us (or allow your employer to provide us with) are:

1. to enable us to comply with our legal obligations; or
2. for the purposes of the legitimate interests pursued by us (and your employer), including the effective running of the pension scheme by the Trustees and Scheme Administrators; or
3. on the basis of your consent (for example, enrolment in voluntary programs or benefits at your direction) from which you may subsequently withdraw at any time by contacting the Scheme Administrators or Trustees, whose contact details are provided at the foot of this Notice, without affecting the lawfulness of processing based on consent before its withdrawal.

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is a legal basis for the further processing and where we have provided notice to you.

For the purposes of the Data Protection Act 2018 / General Data Protection Regulation, the Trustees are the data controller except where the Scheme Actuary is fulfilling certain statutory duties, when the Scheme Actuary and the Trustees are joint data controllers.

Personal information broadly means information that identifies you. This would therefore include any information provided to us in relation to your actual or potential membership of the Pension Scheme when you or your employer contacts us by phone, text, email, post or any other means.

We may hold any or all of the following personal information about you:

• personal details such as your name and any former names, gender, age, date of birth, email address, postal address, telephone or mobile number, IP (internet protocol) address, nationality, long-term sickness details and identifiers such as National Insurance number;
• family, lifestyle and social circumstances such as details about current marriage and partnerships and marital history, details of family and dependents;
• employment details such as pensionable pay, length of service, employment and career history, recruitment and termination details, attendance record, health and safety records, business travel details, security records, job title and job responsibilities, financial details such as income, salary, assets and investments, bank account details to process pension payments, benefits and insurance details.

When we collect personal data from you we store it under strict safekeeping and confidentiality  measures and will limit access to that data. We use technical and organisational security measures to protect it against misuse and any external data processing services, such as the Scheme Administrator and other service providers, must meet our security policies. Your data is held on servers within the European Economic Area (EEA) and elsewhere, such as the United States. We have sought to ensure that an equivalent level of protection is provided for that data. We will take all appropriate steps to ensure that your information is always treated securely and in accordance with this Privacy Notice. Should there be a breach in our security we have procedures in place to manage and rectify this and we have taken all appropriate steps to ensure that all third party service providers have done the same.

We will use your personal information for a number of purposes including the following:

• Scheme administration including calculation of benefits;
• to carry out our obligations arising from any agreement that we have with, or concerning, you and to provide you with the information, benefits and services that you request from us;
• in relation to any correspondence (including queries relating to your membership of the Scheme) related to the administration of the Scheme;
• to notify you about our services and changes to our services;
• anonymously for statistical, financial modelling and reference purposes;
• for internal record keeping;
• risk management, credit risk analysis and analysis of other related risks
• complying with legal and regulatory requirements;
• anonymously in connection with any sale, merger, reorganisation or similar change to the employer’s business.

We will hold your personal information on our systems for as long as is relevant for the purposes for which they were provided, such as ensuring that pension benefits can be paid accurately when members retire. Members (and dependants of members) may make claims relating to their benefits and will refer to events, such as transfers-in, contributions, and periods of service that took place many decades previously. The scheme will therefore hold detailed historical records in order that trustees may consider the claim properly or correct systemic problems that may have been identified at a late stage. 

We may share or disclose your information to any of the following recipients as may be necessary to administer the Scheme and/or comply with contractual obligations relating to it:

• the Scheme administrator;
• your employer;
• our service providers, professional advisers, Scheme actuary and auditors (who in certain circumstances will also be ‘data controllers’);
• HM Revenue and Customs and other regulatory authorities if required to do so by law;
• law enforcement authorities or Courts if required to do so by law;
• insurance companies;
• defined contribution section only, investment managers;
• to potential service providers to fulfil requirements when providing quotes to the Scheme for services;
• persons in connection with any sale, merger, reorganisation or similar change of our business (including any potential or actual purchaser of that business and that purchaser’s advisors);
• external parties as otherwise authorised by you.

Your personal information may be transferred to servers operating in countries outside the European Economic Area (“EEA”), including but not limited to the United States. In addition, our service providers with whom information is shared may be based outside the EEA. Data protection laws may or may not apply in jurisdictions outside the EEA or may not be as stringent as those in the EEA.In any case, we will implement appropriate contractual measures (such as standard data protection clauses) to ensure that the relevant third parties provide an adequate level of protection to your personal information as set out in this notice and as required by applicable law. 

Our Scheme Advisors are currently:

Administrators

Capita

Secretary and Consultants

Capita

Actuary

Martin West, Capita

Investment Managers

Capital Group

Rothschild Wealth Management (UK) Ltd

Morgan Stanley & Co International Ltd

Legal and General Investment Management Ltd

Auditors

Moore Stephens LLP

Bankers

Lloyds Banking Group plc

AVC Providers

Legal & General Investment Management Ltd

Friends Life

Bank of Ireland plc

Legal Advisers

DLA Piper LLP

We will only hold your personal information for as long as it is relevant to your relationship with us or as long as necessary to comply with any legal obligation or to fulfill the above-listed purposes. Details of our data retention policy can be obtained from the Scheme Administrators or Trustees (whose contact details are provided below).

We will take all reasonable steps to ensure that your personal information is kept up-to-date and accurate. From time to time we may ask you to review and update the personal information we hold. In order for us to keep your personal information up-to-date, you must also inform us of any changes to the personal information we hold about you such as your name, address, and contact details.

By providing us with your personal information via by phone, in writing, by email, text or any other means you are giving us your consent to collect, store and process your personal information in the manner described above. The information we hold will be accurate and up to date within our knowledge. 

You have the right to ask for a copy of the personal information that we hold about you and, in certain circumstances, to ask us to correct any inaccuracies in that information,  restrict processing of the data, port (transfer) your personal data to another organisation, or to delete such records. If you would like to have a copy of this information or to ask for more information regarding how to exercise the above rights, please contact the Scheme Administrators or Trustees:

The Christie Pension and Life Assurance Scheme

Capita plc

Kintyre House

205 West George Street

Glasgow G2 2LW

Tel: 0845 601 0607

Email: wayne.gibson@capita.co.uk

The Christie Pension and Life Assurance

Scheme

c/o Carolyn Collard

Christie Management Ltd

Glyndebourne

Lewes

East Sussex BN8 5UU

Email: carolyn.collard@glyndebourne.com

If you have a privacy concern or a question relating to this notice, please contact the Scheme Administrators or Trustees using the details provided above. 

You have the right to complain to the Information Commissioner’s Office if we have not been able to satisfactorily resolve a problem about our handling of your personal information.

Trustees of the Scheme are:

Gus Christie, Nick Clark, Carolyn Collard, Peter Hewitt, Sarah Hopwood, Karen Stidder. All may be contacted c/o Christie Management Ltd at the address above.

This notice does not create contractual rights or obligations.  The provisions of this notice may be altered by us from time to time.  Any alteration or addition will be notified to you.