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We are the Railways Pension Trustee Company Limited, RAILPEN Limited, RAILPEN Investments Limited (each with its registered address at 100 Liverpool Street, London EC2M 2AT) and each is registered with the Information Commissioner's Office (ICO) as a separate 'data controller' in respect of personal information handled for the Railways Pension Scheme (the 'Scheme'), the BT Police Superannuation Fund, the British Railways Superannuation Fund, or any other pension fund administered by Railpen (each a 'Fund').
We are also a data processor for personal data handled on behalf of our clients in pension schemes such as Zurich, United Utilities and Schneider amongst others.
This privacy notice is intended to give you a clear picture of how we handle and protect your personal information. It describes what we collect about you, why, how it is handled, with whom we share it, and where and how long we handle it before it is securely destroyed.
We handle and protect personal information relating to members of the Schemes (and Funds) we administrate and:
For data protection purposes we justify the handling of any personal information we receive based on:
Below are the purposes we have identified to handle and protect your personal information. *LI indicates the reasons premised upon Legitimate Interests.
Reasons for handling your personal information
| Examples |
Manage security incidents and breaches | Deal with incidents and breaches reported about IT hardware and software holding your information |
| Review rights requests | Review your data protection rights requests and provide you access to or act on requests to change, delete, suppress, object to or appeal against how we handle and protect your information |
| Execute client trading on behalf of Members (LI) | Carry out intersection and external Scheme and TUPE transfers |
| Undertake case committee reviews (LI) | Distribute your information to committee members for example, to decide on benefits to be provided based on ill health retirement |
Make payments following a transfer out of the Schemes (LI) | Support requests to transfer you out of our pension Schemes and to another one |
| Pay benefits at retirement (LI) | Obtain documents such as original birth/marriage certificates or copy of passport/driving licence and bank details so your benefits can be paid to you |
| Update bank details (LI) | Input new bank details received from a member or a bank |
| Record changes of name (LI) | Update records to reflect a change of name following marriage or change of personal circumstances |
Record benefits nominees (LI) | Input details of your nominees provided on Nomination form onto our systems |
| Handle reports of a death (LI) | Handle your reports of deceased members, such as setting up and paying out to dependants and other beneficiaries |
| Handle queries (LI) | Respond to your queries |
| Enrol individuals onto our portal and websites (LI) | Register you on our portal so you can access your pension information there |
Share information with external Scheme advisers (LI) | Share your information with scheme actuaries so they can validate our calculations of the benefits you receive |
| Record Letters of Authority (LI) | Log your Letters of Authority so your proxies can handle your pension on your behalf |
| Provide estimates of benefits and transfer quotes (LI) | Calculate your benefits due to member on retirement or transfer |
| Manage benefits following a Divorce (LI) | Collate and record documentation receiving Scheme details in order to provide benefits to your ex-spouses |
Return original Certificates (LI) | Return, following collation and recording, to you the original certificates that you, your relatives or your representatives etc. supplied to us |
| Ill health and serious ill-health retirement grounds (LI) | Collate documentation relating to your health condition and personal circumstances to support providing you with benefits prior to your retirement on ill-health/serious ill-health grounds |
| Oversee the administration of the pension Schemes (LI) | Investigate, monitor, and prepare control and regulatory reports about how we handle pension benefits, members like you and those related to you and the Schemes more generally |
| Manage TUPE transfers (LI) | Update your records should you be TUPE'd from one section of the RPS (Railways Pension Scheme) Scheme to another |
Enrol new entrants (LI) | Obtain your details to be set up and record that you are a new member of our pension Schemes/other schemes we administrate |
| Oversee our Master Trust (LI) | Oversee the operation of our Master Trust pension Schemes |
| Undertake Quality Assurance reviews (LI) | Monitor the quality of business processes associated with dealing with you and our members |
| Provide legal advice (LI) | Provide legal advice or legal support in relation to Railpen's business |
Approve and post journals (LI) | Post new journals to the ledger in line with good accounting practices |
| Perform bank reconciliations | Reconcile bank transactions to our ledger |
| Carry out banking activities (LI) | Download statements to handle cash as it comes in and out of the business |
| Pay supplier invoices for work rendered (LI) | Pay supplier invoices |
| Manage financial transactions (LI) | Manage CHAPS and BACS transactions in order to pay members and collect contributions |
| Produce treasury forecasts (LI) | Produce forecasts about what cash is in the bank |
Perform control monitoring (LI) | Investigate, monitor, and prepare control and regulatory reports into we handle our accounts |
| Prepare annual accounts (LI) | Produce audited accounts |
| Produce cashflow forecasting (LI) | Provide forecasted payments in and out to our various internal and external stakeholders |
| Manage travel and accommodation booking | Manage Railpen's travel and accommodation bookings |
| Make CHAPS payments (LI) | Make ad hoc payments |
| Manage security incidents (LI) | Manage information security incidents and alert our regulators and those such as you that may be affected |
| Undertake internal audits (LI) | Assess whether our business processes are in line with legislation, regulation, industry best practice and internal policy which may mean accessing information about you |
| Carry out fraud investigations | Investigating suspected attempts of fraud by you to deceive Railpen for your own profit |
| Investigate issues brought to our attention by whistleblowers | Investigate allegations or concerns made via our confidential whistleblowing hotline. This may require reviewing information about you |
*Cookies deployed on our websites and portal are as follows:
Effective Date: 24-Jan-2024
Last Updated: 24-Jan-2024
You can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
If you are using any other web browser, please visit your browser’s official support documents.
In order to handle your personal information for the above reasons we may collect and use the following types of personal information about you and, in some circumstances, your spouse, civil partner, partner or dependants:
| Personal details | Financial details | Details about others |
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We also handle the following 'special categories' or more sensitive personal information:
Health data - information about your health conditions could be collected from you should you apply for ill health or serious ill-health retirement
| Reasons for handling your sensitive and special category personal information | Examples |
| Substantial public interests | for a substantial public interests which are contained in the UK Data Protection Act |
| Vital interests | protect yours or someone else's vital interests - usually by making a disclosure to a third-party to support you or a third party with whom you have some involvement |
| Explicit consent | with your explicit consent from time to time we will need your valid explicit consent to handle your personal information if no other appropriate data protection legal basis exists |
Personal information received by Railpen usually comes from yourself, a current or former employer, government agency, any financial or other advisers or representatives acting on your behalf. We also use several suppliers that allow us to verify the accuracy of personal information handled by us (for example, to trace current addresses or verify its continuing existence).
In certain circumstances, we may ask you for information relating to your health. For example, if you are applying for ill health benefits. In some circumstances, additional medical information may be required from your doctor or appropriate medical adviser. We will explain to you at the time why we need that information and how we intend to use it. You do not have to provide the information requested from you, but there may be a delay in the payment of benefits if that information is not provided.
You may also need to provide us with personal information relating to other people (such as your spouse, civil partner, or dependants) for example when completing a nomination form. When you do so, you will need to check with them that they are happy for you to share their personal information with us and for us to use it in accordance with this privacy notice.
If you are acting on behalf of a child, we may also hold and use your personal information, which will be dealt with on the same basis as set out earlier.
From time to time, we may need to share your information with other parties. Where this is necessary, we are required to comply with all relevant data protection legislation. The types of third parties we may need to share of your information with include:
| Employers and other pension schemes | Professional advisory services | Regulators and government agencies | Suppliers to Railpen |
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Certain third parties (most notably, the Scheme's actuary and other professional advisers) are themselves subject to certain legal or regulatory obligations (including professional codes of practice). They will be responsible for their own handling of the information we share with them.
Our core systems, data, and administration services are all carried out and stored within the UK.
Where it is necessary to transfer personal information i.e. send, store or allow access to your personal information outside the UK we will ensure that the correct safeguard is used so that the data is protected to an equivalent extent as it would be if it remained in the UK. This is usually by transferring to a country that is approved as having essentially equivalent data protections under the UK Adequacy Regulation.
Alternatively, we carry out a Transfer Risk Assessment, and where appropriate, the receiving party putting in place an International Data Transfer Agreement designed by the ICO or the EU's Standard Contractual Clauses with an addendum agreed by the ICO and UK Government to recognise it as a valid control under UK. If necessary and based on our Transfer Risk Assessment, we may ask them to put in place additional measures to protect your personal information.
We are committed to protecting your personal information from loss, misuse, disclosure, alteration, unauthorised access, and destruction. We take all reasonable precautions to safeguard the confidentiality of personal information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Although we make every effort to protect your personal information the transmission of information over the internet is not completely secure. As such, you acknowledge that we cannot guarantee the security of personal information transmitted to us over the internet, and that any such transmission is at your own risk.
Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access (and take steps to ensure that any third parties with whom we share your personal data do the same).
We will only retain your personal information for as long as necessary. Necessity will be based on our legal obligations, regulatory guidance, and industry good practice. We have documented how long we keep records containing personal information and why in policies and standards on retention and destruction.
In some circumstances, we may anonymise your personal information instead of destroying it so that it can no longer be associated with you but where anonymised data can be used to add value to our products and services.
Our standard policy is for information or data to be kept for only as long as necessary for the purposes set out above. It is then disposed of in a managed and secure way. However, as pensions are a long-term saving vehicle, it may be necessary to retain your personal data for the remainder of your life and any dependants' lives in order to determine your entitlement to and pay the benefits you may be entitled to, along with any dependants' benefits payable.
You have several rights under data protection law. These include the right to:
There is also a right in GDPR (General Data Protection Regulation) to receive your personal data (in a structured, commonly used, and machine-readable format) and to transfer your data to another service provider or data controller. This right applies where your data is being processed on the basis of your consent or in line with a contract to which you are party. Please note, that for the majority of members, this is not applicable as we rely on our legitimate business interest to collect and process your data rather than individual consent or contracts.
In order to exercise any of the above rights please write to the DPO (Data Protection Officer) at the address under the 'Our Data Protection Officer' section.
If you fail to provide certain information when requested, we may not be able to provide our services to you (such as paying you your pension), or we may be prevented from complying with our legal obligations (such as to prevent fraud).
We may also not be able to support you if you do not provide us with up-to-date personal information. Therefore, please do keep us updated of any changes in your personal circumstances.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner's Office. Please refer to the ICO website or call them on 0303 123 1113. Of course, we hope that we can resolve your issue quickly and fairly ourselves.
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at DataProtectionTeam@railpen.com or write to:
Railpen
7th Floor
100 Liverpool Street
London
EC2M 2AT
If you are unhappy with how your personal information is being handled, you also have the right to make a complaint to the Information Commissioner's Office, an independent body set up to uphold information rights, which will investigate your complaint.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Railways Pensions is powered by Railpen Limited
© Railpen Limited 2010-2025. Registered Office: 100 Liverpool Street, London EC2M 2AT
Each of Railpen Limited (registered in England and Wales No. 2315380) and Railway Pension Investments Limited (RPIL) (Registered in England and Wales No. 1491097) is a wholly owned subsidiary of Railways Pension Trustee Company Limited (Registered in England and Wales No. 2934539). Registered office for each company: 100 Liverpool Street, London EC2M 2AT. RPIL is authorised and regulated by the Financial Conduct Authority for some of its activities. The administration of occupational pension schemes is not a regulated activity. Full details about the extent of RPIL's authorisation and regulation by the Financial Conduct Authority are available from us on request.
