The Travel Automation Services Limited Retirement Benefits Scheme (the “Scheme”)
Fair Processing Notice
As data controllers, the Trustees of the Scheme, take your privacy very seriously and as such we will process your personal data in accordance with applicable data protection law. We use your personal data that is provided to us to administer and manage your pension and pay you or any person in respect of you the benefits provided by the Scheme. The Trustees can be contacted as follows:
Rob Chandler
Secretary to the Trustees of the Travel Automation Services Limited Retirement Benefits Scheme
Cartwright Benefit Consultants Limited
250 Fowler Avenue, Farnborough Business Park
Farnborough, Hampshire, GU14 7JP
Where any personal data is provided to the appointed Scheme Actuary in connection with their statutory function (or any other function required by the Rules of the Scheme), the Trustees and appointed Scheme Actuary are joint data controllers so long as that personal data is required for the purposes of the Scheme Actuary’s statutory function (or any other function required by the Rules of the Scheme). Other advisers and service providers to the Trustees may also be data controllers or joint data controllers in respect of personal data in relation to the Scheme and must comply with applicable data protection law.
We process the personal data that you provide to us for the purpose of administering and managing your pension and paying you and/or your spouse and dependants benefits. We therefore process your personal data on the legal basis that the processing is necessary to comply with our legal obligations and to further our legitimate interests as trustees of the Scheme. If you do not provide us with the personal data that we specify is required for administration of the Scheme then we may not be able to administer the benefits provided by it.
We may transfer your data to Travelport International Limited and their advisers, the Scheme’s advisers, service providers and partner organisations to the extent that it is necessary for the management and administration of the benefits provided by the Scheme. We may also disclose your information to third parties in order to operate, administer and audit the Scheme responsibly; in the event that Travelport International Limited sells its business or assets (in which case we may disclose your personal data to the prospective buyer), although please note that we are not aware that the sponsoring employer is intending to sell its business; in the event that we decide to de-risk or insure any of the benefits provided by the Scheme (in which case we may disclose your personal data to the prospective insurer) or where we are under a duty to disclose your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the Trustees, the members of the Scheme, or others. We do not use your data for marketing or transfer personal data to other organisations for the purpose of marketing their goods or services.
Your personal data may be processed outside of the European Economic Area (“EEA”) where required in order for us or Travelport International Limited to provide benefits to or in respect of you. In each instance, we have ensured that the processing of your personal data outside the EEA is governed by the Standard Contractual Clauses approved by the European Commission and approved by the UK Data Protection Act and/or Information Commissioner’s Office.
We will keep your personal data stored on our systems for as long as it takes us to provide the pension and other benefits provided under the rules of the Scheme. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our rights. We review our data retention policies regularly and will retain your personal data only as long as necessary for the purpose for which we process that data.
Data Protection legislation gives you the right to access information held about you. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you. Where we or third parties are processing your personal data on the basis that you have consented to that processing then you are entitled to withdraw your consent. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds. However, some data, for example data in relation to your health or personal life, is regarded as ‘special categories of data’. The processing of this data is necessary for carrying out the Trustees’ obligations and giving effect to your specific rights in the field of employment, social security and social protection law under the Data Protection Act 2018 (which covers special categories of data).
You will be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise your data protection rights, including your rights to access, restrict, object to the processing of, rectify and erase your personal data by contacting:
Capita Pension Solutions
PO Box 555
Stead House
Darlington
DL1 9YT
Tel: 01227 773983
E-mail: tasl@capita.co.uk
If you are unhappy with the way in which your personal data is being processed you have a right to lodge a complaint with the Information Commissioner’s Office. You can report your concerns by telephoning their helpline on 0303 123 1113 or through their website at https://ico.org.uk/concerns.
Last Updated: 16 September 2024