This notice is for members and beneficiaries of the Plan. It has been prepared by Dun & Bradstreet (UK) Pension Plan Trustee Company Limited ("Trustee", or "we") in its capacity as trustee of the Plan.
As the trustee of the Plan we hold certain information about you (“personal data”). We are required by law 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.
The Trustee processes personal data about you, in its role as controller, for the proper handling of all matters relating to the Plan, including its administration and management, calculating, securing and paying benefits and managing liabilities in relation to it. Further information about how we process this data is provided under the heading “How we will use your data” below.
The legal basis for our use of your personal data will generally be one or more of the following:
The types of personal data we hold and process about you can include:
We obtain some of this personal data directly from you. We may also obtain data from your current or past employer(s) or companies that succeeded them in business (for example salary information), from a member of the Plan (where you are or could be a beneficiary of the Plan as a consequence of that person’s membership), and from a variety of other sources including public databases, our advisers, and government or regulatory bodies.
Where we obtain information concerning certain “special categories” of particularly sensitive data, such as health information, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation. You have the right to withdraw your consent to the processing at any time by notifying the Trustee in writing. However, if you do not give consent, or subsequently withdraw it, the Trustee may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Plan, please ensure that those individuals are aware of the information contained within this notice.
We may use this data to deal with all matters relating to the Plan, including its administration and management. This can include the processing of your personal data for all or any of the following purposes:
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 Plan. These include the following:
We may also provide some of your data to the Plan’s sponsoring and group companies of those employers, their advisers and potential purchasers of their businesses.
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 legislation to provide you with additional information regarding the personal data that they hold about you and how and why they process that data. Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers direct, for example, via their websites. Separately from the Plan, Dun & Bradstreet (as an employer) is a data controller and has issued its own privacy notice to employees.
In addition, where we make Plan investments or seek to provide benefits for Plan members 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. In each case we will only do this to the extent that we consider the information is reasonably required for these purposes.
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 the information is reasonably required for a legitimate purpose.
Where requested or if we consider that it is reasonably required, we may also provide your personal data to government bodies and dispute resolution and law enforcement organisations, including the courts, the Pensions Regulator, the Pensions Ombudsman, the Pension Protection Fund and Her Majesty’s Revenue and Customs (HMRC). They may then use the data to carry out their legal functions.
In some cases recipients of your personal data may be outside the UK. This means your personal data may be transferred outside the EEA to a jurisdiction that may not offer an equivalent level of protection as is required by EEA countries. If this occurs, appropriate safeguards must be implemented with a view to protecting your data in accordance with applicable laws. Please contact the Trustee, using the contact details below, if you want information about the safeguards that are currently in place.
We will only keep your personal data for as long as we need to in order to fulfil the purposes identified above. In practice this means that we will retain your data for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from the Plan 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 Plan. We may also retain your data for a longer period to comply with our legal and regulatory obligations.
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 is out of date. In some circumstances you may also have a right to ask the Trustee to erase or restrict the processing of your personal data, to object to processing or to transfer your personal data. You can obtain further information about these rights from the Information Commissioner’s Office at: www.ico.org.uk or via their telephone helpline (0303 123 1113).
If you wish to exercise any of these rights or have any queries or concerns regarding the processing of your personal data, please contact the Trustee using the contact details provided below. You also have the right to lodge a complaint in relation to this privacy notice or the Trustee’s processing activities with the Information Commissioner’s Office, you can do this via the ICO’s website or telephone helpline.
The personal data we hold about you is used to administer your Plan benefits and we may from time to time ask for further information from you for this purpose. If you do not provide such information, or ask that the personal data we already hold is deleted or restricted, this may affect the payment of benefits from the Plan. In some cases it could mean the Trustee is unable to put your pension into payment or has to stop your pension (if already in payment).
We strive for continuous improvement in our services, processes and protecting data subject rights. We will therefore update this privacy notice from time to time. Therefore we advise you to check this notice on a regular basis or if requested we will send it to you on a regular basis. We are also happy to provide previous versions of this notice on request.
Please contact the Trustee for further information using the contact details below.
By Email- Secretary@dnbpensionplan.co.uk
By Post- Plan Secretary, Dun & Bradstreet (UK) Pension Plan, The Point, 37 North Wharf Road, London W2 1AF
You now have more options available to you at retirement in terms of how you take your pension… view the video to find out more and to discuss any of this further, contact Friends Life using the details provided under the Contacts tab.
The Barber Judgment and the equal treatment of men and women
Generally speaking pension Plan’s used to have different retirement ages for Men and Women for example; 65 for men and 60 for women. This practice was challenged in the European Court of Justice in 1990 and it was ruled that Trustees must pay equal or comparable benefits to men and women from that date.
How this changed the Dun & Bradstreet Pension Plan
The Dun and Bradstreet Plan equalised normal retirement ages for men and women, before the Barber judgment, on 6 April 1988. Before this date men had a normal retirement age of 65 and women had a normal retirement age of 60.
Any person that joined the Plan after 6 April 1988 has a normal retirement age of 65 regardless of gender.
Any person that joined the Plan before 6 April 1988 has a normal retirement age of 60 for their service between 17 May 1990 to 31 March 2004; a normal retirement age of 65 for service after 31 March 2004; and a normal retirement age of 65 or 60 depending on gender for service before 17 May 1990.