Privacy policy

Introduction and General Terms

1. This Privacy Notice sets out how BT Pension Scheme Trustee Limited, the trustee of the BT Pension Scheme, (“Trustee”, “we”, “us”, “our”) obtains, uses and protects any personal information that you provide to us, or that is otherwise obtained or generated by us, and which relates to you or to any individual connected with you.

2. This Privacy Notice explains the following:

   • what information we may collect about you;

   • keeping 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; and

   • technical information that we may collect about you (including via the use of cookies on our website).

3. By providing us with your personal information (or by allowing your employer to provide us with your personal information), you agree to the processing of your personal information as outlined in this Privacy Notice.

4. For the purposes of the Data Protection Act 1998 (the Act), the data controller is BT Pension Scheme Management Limited | One America Square, 17 Crosswall, London EC3N 2LB, registered number 6009363.

Information we may collect about you

1. How do we collect personal information about you?

   Personal information broadly means information that identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual. This would therefore include any information provided to us in relation to your actual or potential membership of the BT Pension Scheme (the “Scheme”) when you or your employer contacts us online, by phone, text, email, post or any other engagement or correspondence that you or your employer may have with us.

2. What types of personal information may we collect about you?
   
   

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

   • personal details such as your name, gender, age, date of birth, email address, postal address, telephone or mobile number, description of physical or mental health and identifiers such as passport 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, security records, job title and job responsibilities, financial details such as income, salary, assets and investments, bank account details to process pension payments, benefits, grants and insurance details; and

   • technical information and other information about your visits to our website - you can find more information about this in paragraphs 7 and 8, below.

Keeping your information safe

1. Password protection

   • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping such password confidential. Please do not share your password with anyone.

2. Transfers of your information

   • We may transfer, store, or process your personal information at a destination outside the European Economic Area (EEA), such as the United States. Where the countries to which your personal information is transferred may not offer an equivalent level of protection for personal information to the laws of the UK, we will take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Notice.

   • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the safety of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorised access.

What we may use your information for

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

   • to administer the Scheme including to process data to calculate and pay 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;

   • for statistical, financial modelling and reference purposes;

   • for internal record keeping;

   • risk management including credit risk analysis and the insurance of longevity risks and related demographic risks;

   • complying with any present or future law, rule, regulation, guidance or directive, and complying with any industry or professional rules and regulations or any applicable voluntary codes;

   • complying with demands or requests made by local and foreign regulators, governments and law enforcement authorities, and complying with any subpoena or court process, or in connection with any litigation;

   • in connection with any sale, merger, acquisition, disposal, recognition or similar change of our business;

   • to analyse and improve the activities, services and information offered by the BT Pension Scheme website.

2. We will hold your personal information on our systems for as long as is necessary for the relevant activity or services although, if necessary, processing of your information may continue after you have opted out of the Scheme or the cessation of any benefits provided to you by us.

Who we may share your information with

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

   • the Scheme’s administrator (such as BT Pension Scheme Management Limited, and Accenture), BT plc as the sponsoring employer and members of its group of companies and the counterparties to the Scheme’s investments;

   • members of our group of companies;

   • our service providers, professional advisers and auditors ((such as Willis Towers Watson and the Scheme Actuary) who in certain circumstances will also be ‘data controllers’);

   • local or foreign regulators, governments and law enforcement authorities;

   • local and foreign courts, tribunals and arbitrators, other judicial committees or enactments of laws;

   • insurance companies (such as Prudential Insurance Company of America); and

   • persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change of our business (including any potential or actual purchaser of that business and that purchaser’s advisors).

2. From time to time, our website may contain links to and from the websites of our partner organisations and advertisers. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these organisations or their activities. Please check these policies before you submit any personal information to these websites.

Your rights regarding the personal information you provide to us

1. The accuracy of the information we hold about you is important to us. Under the Act you have the right to access the information we hold about you and have any inaccuracies corrected. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

2. If any of the information we hold about you is inaccurate or out of date or you object to us processing it, please let us know using the contact details further down.

Technical information that we may collect about you

When you visit our website, we may collect technical information about your computer, such as your internet protocol address (which is a number that can uniquely identify a specific computer on the internet), your login information, browser type and version, browser plug-in types and versions, operating systems and platforms. We may also collect information about your visit, including [the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Cookies

1. Our website uses cookies to distinguish you from other users of our website. A cookie is a small file, typically consisting of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device, and by analysing the data from cookies we can improve our website and the associated user experience. For a copy of our Cookie Policy please click on the following link [insert link].

2. By continuing to browse our website, you are agreeing to our use of cookies.

3. Please note that third parties (including, for example providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies, but may include other types of cookies.

4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Changes to our Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website. Your use of the website, or continued participation in the Scheme, following these changes means that you accept the revised Privacy Notice.

Contact

If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:

By post:

BT Pension Scheme c/o Accenture
Venture House
Venture Way
Chesterfield
Derbyshire
S41 8NR

By email: btpensions@accenture.com

By phone:

• from within the UK: 0800 731 1919

• from outside the UK: +44 (0)203 0233420