Valid from July 2024

PRIVACY NOTICE
for Sandvik UK Group Defined Benefit Pension Plan (the "Scheme")
This privacy notice is for members and beneficiaries of the Scheme. It has been prepared by
Alison Ronnie, Joseph Alan Boulton, Andy Taylor, Peter Rose, John Eustace, Lynn Disbery
and Michael Fleming (the "Trustees", or "we") in their capacity as trustees of the Scheme.
The Trustees are registered as a controller of personal data with the Information
Commissioner’s Office ("ICO").
This privacy notice replaces the Scheme’s previous privacy notice from 2019 and supplements
any other notices and statements we issue that are specific to particular data collection /processing activities.
Why we are providing this notice to you
As the trustees of the Scheme we hold certain information about you and from which you canbe identified (either from the information itself or with other information that we may hold)("personal data"). In line with the transparency requirements of applicable data protection
laws, we are required to give you specified information about the personal data we hold about
you, how we use it, and the safeguards that are in place to protect it. This notice is designed
to give you that information.
Why we process your personal data
The Trustees process personal data about you, in their role as controller, for the proper
handling of all matters relating to the Scheme, including its administration and management,
calculating, securing and paying benefits and managing liabilities in relation to it.
Details regarding how and why we process your personal data and the legal bases relied onby the Trustees when carrying out this processing is set out in the Schedule. The Schedulealso provides information concerning the conditions that we rely upon when processing"special categories" of particularly sensitive personal data.
What personal data we hold and how we obtain it
Please refer to the Schedule for information concerning the types of personal data we holdand process about you.
We obtain some of this personal data directly from you. We may also obtain data from yourcurrent or past employer(s) or companies that succeeded them in business (for example salary
information), from a member of the Scheme (where you are or could be a beneficiary of the
Scheme as a consequence of that person's membership), and from a variety of other sources
including data tracing agencies, public databases, our advisers, additional voluntary
contribution (AVC) arrangement providers, and government or regulatory bodies.
Where you have provided us with personal data about other individuals, such as family
members, dependants or potential beneficiaries under the Scheme, please ensure that thoseindividuals are aware of the information contained within this notice.

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How we will use your personal data
We may use this data to deal with all matters relating to the Scheme, including its
administration and management. For further information, please refer to the Schedule.
Organisations that we may share your personal data with
From time to time, we will share your personal data with our advisers and service providers
so that they can help us carry out our duties, rights and discretions in relation to the Scheme.
These include the following advisers and service providers (for some advisers/providers wehave provided links facilitating access to their privacy notices, which provides information
about how they address their obligations in relation to personal data).
•
•
•
•
•
•
•

The Scheme administrator, currently Aptia, whose privacy notice can be found athttps://aptia-group.com/en-gb/privacy-notice?language=en-gb
The legal advisers to the Trustees, currently Squire Patton Boggs (UK) LLP, whose
privacy notice can be found at https://www.squirepattonboggs.com/en/footer/privacy
The Scheme actuary, currently Dave Robinson of Mercer, whose privacy notice can befound at https://www.mercer.com/en-gb/footer/privacy-notice/
Actuarial consultants, currently Mercer
The Scheme auditors, currently Deloitte LLP whose privacy notice can be found athttps://www.deloitte.com/uk/en/legal/privacy.html
Investment advisers, currently Mercer
AVC arrangement providers, currently Scottish Widows, Utmost Life and Pensions,Prudential Life and Phoenix Life whose privacy notices can be found at:
○
○
○
○

•
•
•
•

https://www.scottishwidows.co.uk/legal-information/privacy.html
https://www.utmost.co.uk/privacy-notice/https://www.mandg.com/pru/customer/en-gb/footer/privacy-security
https://www.phoenixlife.co.uk/legal-and-policies/privacy-notice

Tracing bureaus for mortality screening and locating members and beneficiaries
The Trustees’ insurers
The Scheme's banks
Suppliers of IT, document production and distribution services

In some instances, advisers and service providers will be controllers in their own right and will
be directly responsible to you for their use of your personal data. They may be obliged under
the data protection laws to provide you with additional information regarding the personal datathat they hold about you and how and why they process that data. Further information may beprovided to you in a separate notice or may be obtained from the advisers and service
providers directly, for example, via their websites. Whenever one of our advisers or service
providers acts as a joint controller with us in respect of your personal data, because we jointly
determine the purposes and means of processing it, we will agree with them how we are eachgoing to meet our respective and collective obligations under the data protection laws. If you
would like more information about how such an arrangement works, please contact us using
the contact details below.
We may also provide some of your data to the Scheme's sponsoring employer (Sandvik
Holdings Limited) and group companies of those employers, their advisers and potential
purchasers of their businesses.

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In addition, where we make investments or seek to provide benefits for Scheme members andother beneficiaries in other ways, such as through the use of insurance or pension scheme
mergers, then we may need to share personal data with providers of investments, insurers
and other pension scheme operators.
The advisers, service providers and organisations referred to in the paragraphs above may
use personal data to perform their functions as well as for statistical and financial modelling(such as calculating expected average benefit costs and mortality rates) and planning,business administration and regulatory purposes. They may also pass the data to other third
parties (for example, insurers may pass personal data to other insurance companies for the
purpose of obtaining reinsurance), to the extent they consider it appropriate to do so.
Where requested or if we consider that it is reasonably required, we may also provide yourpersonal data to:•••pensions dashboards (for further information about pensions dashboards, please referto the Money & Pensions Service website ( https://maps.org.uk/en/our-work/pensions );the Pension Protection Fund; andgovernment bodies, regulators and dispute resolution and law enforcement
organisations (including the courts, the Pensions Regulator, the Pensions Ombudsman,and HMRC).

They may then use the data to carry out their functions.
Transferring personal data outside the UK
In some cases, recipients of your personal data may be outside the UK. This may include thegroup companies associated with the Scheme's sponsoring employer and their professional
advisors as applicable. It may also include affiliates / overseas offices of the Scheme's service
providers, including Aptia, Mercer and Squire Patton Boggs. This means your personal data
may be transferred outside the UK to a jurisdiction that may not offer an equivalent level ofprotection as is provided in the UK.
Additional safeguards are in place to protect your personal data when we (or service providers
who process personal data on our behalf) transfer it outside the UK as at least one of thefollowing measures is relied on:••

the transfer is to a country that has been deemed to provide an adequate level ofprotection for personal data by the UK Secretary of State; orstandard contractual clauses (approved by the relevant governmental or supervisory
authority) are in place with the recipient of the data, requiring your personal data to besafeguarded in accordance with applicable laws.

Please contact the Trustees using the contact details below, if you require further information
about the safeguards that have been adopted or would like to request (free of charge) a copy
of applicable standard contractual clauses that we use in relation to the processing of yourpersonal data.
How long we keep your personal data
We will only keep your personal data for as long as we need to in order to fulfil the purposes
identified above and detailed further in the Schedule. In practice this means that we will retain
your data for such period as you (or any beneficiary who receives benefits after your death)31470589586\6\EUROPE

are entitled to benefits from the Scheme and for so long afterwards as may be required to deal
with any questions, complaints or claims that we may receive about our administration of the
Scheme. We may also retain your data for a longer period to comply with our legal andregulatory obligations.
Your rights
You have a right to access and obtain a copy of the personal data that the Trustee holds
about you, and to ask the Trustee to correct your personal data if there are any errors or it isout of date or incomplete.
You have a right to ask the Trustee to erase your personal data where it is being processedon a legal ground other than for complying with a legal obligation and where:••••

you believe we no longer need to process the personal data for the purposes identified
above and detailed further in the Schedule;
you had given consent to the processing of the personal data but you subsequently
withdraw your consent and there is no other lawful basis upon which we can process
the personal data;
the personal data has been processed unlawfully or it has not been erased when it
should have been; oryou have been successful in objecting to the processing.

In some cases, you may also have a right to request that the processing of your personal data
be restricted or to transfer your personal data (for example, to another pension scheme).
In certain circumstances, you also have the right to object to the processing of your personaldata, for example:••

where we rely on legitimate interests as our lawful basis for processing; in which case,
we must carry out an exercise balancing our legitimate interests with your rights andfreedoms as a data subject (if you disagree with the outcome of that balancing exercise
you have the right to refer the matter to the ICO); or
where the processing is for direct marketing purposes.

Where we rely upon your consent to lawfully process your personal data, including explicit
consent, you have the right to withdraw your consent to the processing at any time bynotifying the Trustees in writing. Withdrawal of consent will not affect the lawfulness ofprocessing based on your consent before it is withdrawn.
You can obtain further information about these rights from the ICO at: www.ico.org.uk or via
its telephone helpline (0303 123 1113).
If you wish to exercise any of these rights or have any queries or concerns regarding theprocessing of your personal data, please contact the Trustees using the contact details
provided below. You can also lodge a complaint in relation to this privacy notice or the
Trustees' processing activities with the ICO - you can do this via the ICO's website or
telephone helpline.
As explained in this privacy notice, one of the reasons we collect and hold your personal datais to administer your Scheme benefits. If you do not provide the information we request,
withdraw your consent to the processing, or ask that the personal data we already hold isdeleted or that the processing of the personal data be restricted, this may affect our ability to
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administer your benefits, including the payment of benefits from the Scheme. In some cases
it could mean the Trustees are unable to put your pension into payment or have to stop yourpension (if already in payment).
Updates
We may update this notice periodically. Where we do this, we will inform you of the changes
and the date on which the changes take effect.
Contacting us
Please contact the Trustees for further information using the contact details below:
Trustees of the Sandvik UK Group Defined Benefit Pension Plan
Aptia UK Limited
Post Handling Centre
Maclaren House
Talbot Road, Stretford
Manchester
M32 0FP
pensionuk.aptia-group.com

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How and why we process your personal data
There are six lawful bases for processing personal data under the UK GDPR and the Trustees ("we","us" or "our") must rely on at least one of these whenever we process your personal data. The six
lawful bases are summarised below.
No

Lawful Basis

Description

1

Consent

You have consented to us processing your personal data for one ormore specific purposes.

2

Contract

The processing is necessary for the performance of a contract which
you are a party to, or in order to take steps at your request prior toentering into a contract.

3

Legal obligation

The processing is necessary for compliance with our legal obligations
as a trustee of an occupational pension scheme.

4

Vital interests

The processing is necessary in order to protect your vital interests or
those of another person (vital interests are interests that are essential
for someone’s life, for example, emergency medical care).

5

Public task
authority

6

Legitimate interest

or

official

The processing is necessary for the performance of a task in the public
interest or so that we can exercise any official authority that we havevested in us.
The processing is necessary for legitimate interests pursued by us or
the legitimate interests of a third party, unless there is a good reason toprotect your personal data which overrides those legitimate interests.

Our legal grounds for processing your personal data are set out in the table below. If you have any
comments or concerns about our use of your personal data (including as described below) pleasecontact us directly via the contact details listed above.

PRIMARYUSE OFYOURPERSONALDATAPERSONAL DATA WE
HOLDEXAMPLE USES OF YOURPERSONAL DATALAWFUL BASISRELIED ON FOR
PROCESSING

Administeringand managing
the Scheme
andtheliabilities
under itName, date of birth, sex,
gender, address, telephone
number,email
address,national insurance number,
employeeandmembership/reference
numbers and copies of
documentation verifying your•

3 We haveobligations to:••

To identify you and tocreateanaccurate
member record on oursystems.
To correspond with andanswer queries from you
and your advisers.
To assess eligibility or

•

legal

provide you (andanyone else withan entitlement) withthe correct level ofbenefits under the
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PRIMARYUSE OFYOURPERSONALDATAPERSONAL DATA WE
HOLD

identity.
Information")("General

Bank accountdetails.
Information")

details, tax("Financial

Information about your family
and dependents, including
your marital status, dependantdetails, next of kin, andinformation
about
your
personal
relationships.
("Family Information")
Information used to calculate
and assess eligibility forbenefits, such as details ofpensioncontributions,employment history, length ofpensionable service, scheme
retirement
date,
salary/remuneration
information,
investment
choices,
preferences
regarding the distribution ofdeath
benefits,
benefits
accrued in, paid out ortransferred to/from this (andother) pension arrangements,tax
andcontracting-out
records.
("Benefit
Information")
Additional personal data that
we request from you in orderto action a request from you totransfer your benefits out ofthe
Scheme.
("Transfer
Information")
Personal data concerning
your health, or the health ofanother who may receive
benefits as a consequence ofyour membership or benefits
in the Scheme. ("Health
Information")

EXAMPLE USES OF YOURPERSONAL DATA••

continuing eligibility forbenefits.
To
calculate,adjust,allocate and pay benefits(including
benefits
payable in the event of
your death).
To provide you withcertain information which
we either:
○
○

•

•

•

•

•

•

•

are legally required toprovide you with; or
consider is relevant toyou as a member of
the Scheme.

To report to and liaise with
HMRC and facilitate thepayment of any tax due inconnection with yourbenefits.
Managing the investmentof Scheme funds andfacilitating the investmentof any money purchasepension savings you may
have which are linked with
the Scheme (including in
AVC arrangements).
To
assessand,ifappropriate, action arequest you make totransfer your benefits outof the Scheme.
To identify your potential
benefit options and, where
relevant, implement those
options.
To calculate and reconcile
contributions
paidorpayable.
Ensuring compliance withrequirements arising frommembers of the Scheme
contracting-out of theState Second Pension.
Preparation of Scheme

LAWFUL BASISRELIED ON FOR
PROCESSING••

Scheme;comply with tax andcontracting-out
legislation
anddeduct the correct
level of tax from
benefits; andmanageandadministerthe
Schemeinaccordance with its
governing
documents
andapplicablelegislation.

6 The processing isnecessaryforthelegitimate interests ofadministeringandmanaging the Schemeand the liabilities under
it.

Where
HealthInformation is being
processed, please refer
to Note 1 below.
Where
Criminal
Information is being
processed, please refer
to Note 2 below.
If and to the extent
sexual orientation is“special category” data,
please refer to Note 3
below.

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PRIMARYUSE OFYOURPERSONALDATAPERSONAL DATA WE
HOLD

Personal data relating tocriminal
convictions
andoffences.
("Criminal
Information")

EXAMPLE USES OF YOURPERSONAL DATA

•

•

•

•

•

accounts, valuations andaudits.
The
operation
andmaintenanceofandprovision of information
via the Scheme’s member
portal.
To allow alternative waysof delivering your benefits,
for example, through theuse of insurance products
and transfers to or
mergerswithotherpension arrangements.
To manage the Scheme's
liabilities, including theentering into of insurance
arrangements, arranging
for insurers to take over
responsibility
forthepayment of benefits, andthe selection of Scheme
investments.
For
statisticalandfinancial modelling andreference purposes.
To liaise with, or respondto orders or requests from○○•LAWFUL BASISRELIED ON FOR
PROCESSING

the
PensionProtection Fund; andgovernment
bodiesand dispute resolution
and law enforcement
organisations,
including the courts,
thePensions
Regulator,
thePensions
Ombudsman,
and
HMRC.

To comply with our duties
in respect of pensions
dashboards (for further
informationabout
pensions
dashboards,
please refer to the Money
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PRIMARYUSE OFYOURPERSONALDATAPERSONAL DATA WE
HOLDEXAMPLE USES OF YOURPERSONAL DATALAWFUL BASISRELIED ON FOR
PROCESSING&
Pensions
Servicewebsite(https://maps.org.uk/en/o
ur-work/pensions)).
Addressing
any actual or
potential
disputes
relating to the
Scheme orconnected
with yourmembershipor benefit
entitlements
under theScheme

•
•
•
•
•
•
•

General Information
Financial Information
Family Information
Benefit Information
Transfer Information
Health Information
Criminal Information

To respond to or deal with any
queries,
concerns
anddisputes which relate to the
Scheme, your membership ofor benefit entitlements under
the Scheme. This shall include
actual or potential disputes
raised under the Scheme'sInternal Dispute Resolution
Procedure, or with thePensions Ombudsman or the
courts.

3 We haveobligations to:
•

•

•

legal

put in place andobserve a formal
procedure
andprocesstoinvestigate
anddecideupon
disputes relating to
the Scheme, inrespect of persons
with an interest in
the Scheme;
engagewithformalities
associatedwithproceedings
brought
beforejudicial
bodies,includingthePensions
Ombudsman andthe courts; andcomplywith
directions or ordersof judicial bodies.

6 The processing isnecessaryforthelegitimate interests ofinvestigating, pursuing
and/ordefending,actualorpotential
disputes.
Where
HealthInformation is being
processed, please refer
to Note 1 below.
Where
Criminal
Information is being
processed, please
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PRIMARYUSE OFYOURPERSONALDATAPERSONAL DATA WE
HOLDEXAMPLE USES OF YOURPERSONAL DATALAWFUL BASISRELIED ON FOR
PROCESSING

refer tobelow.
Liaison withcurrent orformersponsoring
employers of
the Scheme(including inconnection
with acorporatetransaction)

•
•
•
•
•
•

General Information
Financial Information
Family Information
Benefit Information
Health Information
Criminal Information

To correspond with thesponsoring employers of the
Scheme in connection withyour
employment,
theirobligations as employers, orchanges to the Scheme orbenefits payable from the
Scheme.
To process your personal datain connection with the sale,mergeror
corporate
reorganisationoftheemployers that sponsor the
Scheme and their groupcompanies.

Note

2

6
Processing
isnecessaryforthelegitimate interests of:••enabling
sponsoring
employers
tocomply with their
obligations
asemployers; andaddressing issues
arising in relation tocorporatetransactions
andreorganisations.

Where
HealthInformation is being
processed, please refer
to Note 1 below.
Where
Criminal
Information is being
processed, please refer
to Note 2 below.

Note 1
Where Health Information is being processed for the purpose of assessing eligibility for benefits fromthe Scheme, we will rely upon the data subject's explicit consent as the lawful condition for thatprocessing.
Where eligibility has been assessed and Health Information is retained for our own records, we will rely
upon the following lawful conditions, in addition to the lawful bases specified in the table above.
••

The processing is necessary for the purposes of carrying out the obligations and exercising
specific rights in the field of employment and social security and social protection law.
The processing is necessary for the establishment, exercise or defence of legal claims.

Note 2
Where Criminal Information is being processed, we will rely upon the following lawful conditions, inaddition to the lawful bases specified in the table above.
••

The processing is necessary for the purposes of carrying out the obligations and exercising
specific rights in the field of employment and social security and social protection law.
The processing is necessary for the purposes of establishing, exercising or defending legal rights.
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Note 3
If and to the extent sexual orientation is “special category” data, we will rely upon the following lawful
conditions, in addition to the lawful bases specified in the table above.
••

The processing is necessary for the purposes of carrying out the obligations and exercising
specific rights in the field of employment and social security and social protection law.
The processing is necessary for the establishment, exercise or defence of legal claims.

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