Mastertrust Privacy Notice

Last updated: April 2024

1. Introduction

This privacy notice is issued by the Trustees of the Legal & General WorkSave Mastertrust, the Legal & General WorkSave Mastertrust (RAS) and the Legal & General Group Life Mastertrust. It only applies to members of these arrangements.

If you also have products or services which are provided by Legal & General, they are covered by a separate privacy notice, which is available here: www.legalandgeneral.com/privacy-notice.

Please note that we will not use your information for marketing purposes unless you specifically give consent for us to do so.

2. The Aim of this Notice

Protecting your Personal Information is extremely important to the Trustees and the way we collect, store, process and share your information is equally important. Our members expect us to manage their information privately and securely.

This notice tells you how we collect and process your Personal Information. Please take a few minutes to read it. Most of the activity associated with managing your pension account and / or life assurance benefit is undertaken by Legal & General Assurance Society (known as LGAS) on behalf of the Trustees. LGAS must comply with data protection laws in the same way as the Trustees; a link to the LGAS privacy notice is provided above.

3. What is Personal Information?

When we talk about Personal Information we mean information about an individual that can identify them, such as their name, address, e-mail address, telephone number and financial details. It can relate to members, their appointed representatives (e.g. your financial adviser, power of attorney or any other third party appointed by you), employees, business contacts and suppliers. Any reference to “information” or “data” in this notice is a reference to Personal Information about a living individual.

4. What Personal Information do we hold?

We may collect and process the following Personal Information about you:

5. Where do we get our Personal Information from?

• Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).
  Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
• Information we collect about you or receive from other sources.
  This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, information from a third party (e.g pension provider, tracing agencies and credit reference agencies) or from publicly available sources such as social media platforms or the electoral register (e.g. to detect fraudulent activity). We may also receive information if you have been dealing with a financial adviser or from your employer (or their advisers) or HM Revenue and Customs.

For further information on how cookies are used, please refer to the LGAS cookie policy.

6. How do we use your Personal Information?

We use the Personal Information that we hold about you in a number of ways. Such as:

• To carry out our responsibilities, to administer your pension account and / or life assurance benefit, and to supply you with the information and the services that we have agreed to provide to you.
• To tell you about any changes to the way the Mastertrust is run, or to the services we provide to you.
• For statistical, financial modelling, accounting and reference purposes.
• To comply with any applicable legal or regulatory requirements (including “know your customer” checks) or to comply with any applicable regulatory reporting or disclosure requirements - including any relevant industry or professional rules or any applicable voluntary standards.
• To comply with demands or requests made by any relevant regulator, government department and law enforcement or tax authorities or in connection with any disputes or litigation.
• For carrying out market research, statistical analysis and customer profiling, to help us to improve our processes and services and make improvements to the way the Mastertrust operates (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications).
• To run the Mastertrust in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
• For any other purpose that we’ve agreed with you from time to time.

When you become a member of the Mastertrust, the documents you receive may contain additional conditions relating to the way we use and process your Personal Information. These will apply in addition to the above uses.

In some cases, we may use systems to make automated decisions (including profiling) based on the Personal Information we have, or collect from others. Principally, the automated decisions will be carried out in connection with servicing activities. These may include:

• The prevention and detection of fraud and financial crime.
• To perform transaction monitoring, identity verification, money laundering and sanctions checks, and to identify politically exposed individuals. We are required by law to perform these activities which may be achieved using solely automated means to make decisions about you or any individual related to your pension account. We may use these activities to decline the services you have requested or to stop providing existing services to you.
• Servicing activities such as (i) personalising the content and design of communications and online services (such as My Account) in order to service the account and to issue regulatory communications; and (ii) Determining when to provide tailored communications about your Pension account (e.g. as a result of changes in your personal circumstances or lifestyle) and the appropriate channel(s) to use for the purposes of providing regulatory communications.
• These may be achieved using profiling in order to predict certain characteristics about you (e.g. your economic situation, interests, personal preferences or transactional behaviour), although this information will not be used to make decisions about you (other than as already set out above) and the activities will not otherwise have a detrimental effect on you.

We will not use your information for marketing purposes unless you specifically give consent for us to do so.

7. Using your Personal Information in accordance with Data Protection Laws

Data protection laws require us to meet certain conditions before we are allowed to use your Personal Information in the way we describe in this privacy notice. We take these responsibilities extremely seriously, as do all our service providers and advisers. To use your Personal Information, we will rely on the following conditions, depending on the activities we are carrying out:

• Providing our contracts and services to you: We will process your Personal Information to meet any legal responsibilities we have to you as a member of the Mastertrust.
• Complying with applicable laws: We may process your Personal Information to comply with any legal obligations we are subject to.
• Legitimate interests: To use your personal data for many of the purposes described in this privacy notice, we will rely on a condition known as "legitimate interests". It is in our legitimate interest to collect your personal data as it provides us with the information that we need to administer your pension account or your life assurance benefit. We may use your information to:
  • Administer your pension account and / or life assurance benefit, and provide you with connected services (which may include online services).
  • Carry out market research and product development, which can include creating customer demographics and/or profiling. We may sometimes work with carefully selected third parties to do this.
  • Study and also manage how members of the Mastertrust use their pension accounts and the connected services, including member surveys.
  • Manage risk for the Trustees and members.

These tasks involve assessing whether our use of personal data is consistent with your interests and those of other members of the Mastertrust; we also take into account the interests you have as a citizen and the rights you have under data protection laws. The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy notice. We will always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

• Consent: In certain circumstances we may ask for your consent to process data, and where we make this request we will only process the data once we receive your permission. Once you have given your consent you can withdraw it at any time by writing to us using the contact details set out in this notice.
• Special category (sensitive) data: Where you have consented, we will process any medical and health, sex life and sexual orientation information you have provided (including where this information may be inferred from an expression of wish form or from your address if living in communal accommodation) and any other sensitive information obtained from a third party (e.g. your GP or other medical professional), solely for the purposes of allowing us to administer your pension account and / or life assurance benefit and deal with claims and/or queries. Alternatively, we may process special category data for reasons of substantial public interest in accordance with applicable law. We will only process data that is needed for specific purposes.
• Criminal Conviction Data: Where necessary to meet legal obligations, , we may process this type of information solely for the purposes of allowing us to administer your pension account and / or life assurance benefit and also for the prevention of financial crime. For example, this could be inferred from current or historic address information.

Please be aware that the Personal Information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.

8. How long do we keep your Personal Information for?

We have policies that govern how long we keep your Personal Information. Our current notice is to hold Personal Information about members of the Mastertrust indefinitely. This is so that we can meet our obligations to administer your benefits, and to provide protection for you and your dependants / beneficiaries (for example in case you have any questions in the future about how your pension benefits were calculated). We also need to retain this information where required by applicable law or regulatory requirements, as well for the pursuit or defence of legal claims.

9. Who do we share your Personal Information with?

We will only disclose your information to:

• LGAS (the administrators) and other companies within the Legal & General Group who are involved in running the Mastertrust, along with our other third-party suppliers, contractors and service providers for the purposes listed under “HOW WE USE YOUR INFORMATION” above.
• Our regulators, government (e.g. HMRC) and law enforcement or fraud prevention agencies as well as our professional advisers etc.
• Additionally, we may disclose your Personal Information to third parties – for example:
• If you have been dealing with a financial adviser, and you ask us to provide them with information.
• If you are making retirement decisions or considering purchasing an annuity we may provide your information to a financial adviser or annuity broker where you ask us to.
• In certain cases we may share some details of your pension account and / or life assurance benefit with your employer and a professional adviser(s) they might appoint on their (or your) behalf. As an example, we may share the value of your pension account with them if an online benefits portal is made available to you through your workplace. In which case, we will always make sure that there are adequate data protection terms in place before disclosing the information.
• If the Mastertrust (or the relevant part of Legal & General’s workplace pensions business) were acquired by a third party, personal data held by us about members could be transferred.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

The entities listed above may also share personal data with their own business suppliers, for example in relation to the operation of IT systems or where they outsource part of their services. Some of these entities may also be controllers under the Data Protection Laws. However, in the first instance you should use the contact details below if you have any questions about how your Personal Information is used.

Please note that some of the Mastertrust’s former service providers may continue to hold information about you for their own record keeping purposes once they have ceased to be involved with the Mastertrust.

10. Fraud prevention

There may be occasions when the Trustees are required to check your details with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases.

The Trustees and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please write to the Legal & General Group Financial Crime department if you wish to receive the relevant details of the fraud prevention agencies. Their address is:

Group Financial Crime
Legal & General Assurance Society Ltd
Four Central Square
Cardiff CF10 1FS

The Trustees may also check the details of other parties related to your pension account and / or life assurance benefit, including verification of identity. This includes beneficiaries, Trustees, executors or administrators of your estate, parties with power of attorney and any other beneficial owner.

11. Protecting your data outside the UK

The data that we collect from you may be transferred to, and stored at, a destination outside the UK to third-party suppliers, delegates or agents. We will take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy to ensure your personal information is handled with the same protections that we apply ourselves.

We will only transfer your data to a recipient outside the UK where we are permitted to do so by law (for instance):

1. where the transfer is based on standard data protection clauses adopted or approved by the UK’s Information Commissioner’s Office.
2. where the transfer is to a territory that is deemed adequate by the UK , or
3. where the recipient is subject to an approved certification mechanism and the Personal Information is subject to appropriate safeguards, etc.

12. Your Rights

You have rights under data protection laws that relate to the way we, and LGAS as the Mastertrust administrators, process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any these rights, please call us on 0345 070 8686 or contact us by email at employerdedicatedteam@landg.com.

We will normally aim to respond to any request received from you within one month from your request. Access to your data will usually be provided free of charge although in certain circumstances we may make a small charge where entitled to do so under data protection laws.

Your Rights:

1. The right to be informed about how we process your personsl information. This right is met by the provision of this document,
2. The right to access the personal data that we hold about you.
3. The right to make us correct any inaccurate personal data we hold about you.
4. The right to make us erase any personal data we hold about you. This right will only apply where for example):
   1. We no longer need to use the personal data to achieve the purpose we collected it for ii. You withdraw your consent if we are using your personal data based on that consent
   2. Where you object to the way we use your data, and there is no overriding legitimate interest.
5. The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
   1. You dispute the accuracy of the personal data we hold
   2. You would like your data erased, but we require to hold it in order to stop its processing
   3. You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
   4. Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
6. The right to object to our processing of personal data we hold (including the use of your personal information for profiling purposes).
7. The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
8. The right to withdraw your consent, where we are relying on it to use your personal data. This only Legal & General WorkSave Mastertrust - Risk Management Framework 9 applies where we’re relying on your consent in order to use your personal data.
9. For automated decisions (including profiling), you have the right to
   1. obtain an explanation of the decision and challenge it
   2. Request for the decision to be reviewed by a human being.

Please be aware that your Personal Information is required for us to continue administering your pension account and / or life assurance benefit. So even though you have the above rights, we will always need to hold a certain amount of Personal Information in order to administer your account. – please see section 8 “How long do we keep your Personal Information”.

13. Contacts and Complaints

If you have any questions about this privacy policy, or wish to exercise any of your rights, please call us on 0345 070 8686 or email at employerdedicatedteam@landg.com. If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

In addition, further information can be found on the Information Commissioner’s website ico.org.uk.