Purpose of this document
The purpose of this document is to explain and provide notice about what personal data Towers Watson Limited (“Willis Towers Watson”) uses in providing actuarial services in the UK and why we need to use such data. This document does not apply to pensions administration services provided by Willis Towers Watson.
Definitions and the Data Protection Act 1998
Personal data is data which enables a living individual to be identified. The Data Protection Act 1998 (“the Act”) sets out certain responsibilities on how personal data in the UK is handled. The Act categorises organisations or individuals as data controllers or data processors, depending on how such personal data is used, and data controllers and data processors have different responsibilities in relation to such personal data. If you wish to know more about the obligations under the Act generally you can find more information here.
Role of Willis Towers Watson and its use of personal data
Willis Towers Watson advises pension scheme trustees on matters such as:
- the value of an individual member's pension (for example, if a request is made to transfer to another scheme);
- the value of options available to individual members;
- the value of the scheme as a whole;
- the levels of funding that the pension scheme needs; and
- the investment plan for the scheme.
and in so doing, may use members’ data in order to provide services in accordance with its terms of appointment, professional guidance and for statistical and research purposes.
Our policy is to use data which does not identify individuals, wherever possible.
In order to provide our services, the types of personal data that we use about a member may include:
- date of birth
- service dates in the scheme
- salary and pension amounts
- marital status
- whether a pension in payment resulted from ill health retirement
What is the 'scheme actuary'?
The Pensions Act 1995 states that some valuations or advice must be provided by a 'scheme actuary'. This is an individual actuary (who will be a Willis Towers Watson employee) who is appointed by the trustees of the scheme. Some of the advice that we provide to pension schemes is provided by the scheme actuary. Other advice may be provided by other individuals who work for Willis Towers Watson.
The name of the scheme actuary for your pension scheme will be set out in the scheme’s annual report, which can be obtained from the trustees of the pension scheme (see the annual benefit statement or summary funding statement for their contact details).
How does the Data Protection Act apply to this?
In most cases the trustees of a pension scheme are 'data controllers' for the purposes of the Act. For some assignments, Willis Towers Watson and/or the scheme actuary may also be data controllers. The trustees, and Willis Towers Watson and/or the scheme actuary to the extent that they are data controllers, all have a responsibility to use personal data about members in a way that complies with the Act.
In these circumstances, the scheme actuary is responsible:
- for deciding what personal data he or she needs about members so as to perform his or her duties to the trustees. This is likely to involve use of similar categories of members’ data as highlighted above;
- for using this personal data in accordance with his or her terms of appointment and professional guidance; and
- for keeping this personal data secure relying on Willis Towers Watson infrastructure as appropriate.
Willis Towers Watson is responsible:
- for using this personal data in accordance with its terms of appointment and professional guidance;
- for ensuring that appropriate security measures are in place to protect personal data; and
- for ensuring that there is appropriate protection for any personal data which we process outside the European Economic Area or where any personal data is provided by Willis Towers Watson to third parties assisting us in providing the services outlined above
More information and the Institute and Faculty of Actuaries guidance
Please contact the pension scheme trustees about any queries about the use of member personal data, in the first instance.
General guidance is available from the Information Commissioner's website.
The Institute and Faculty of Actuaries (IFoA) has published guidance on data protection and the role of scheme actuaries.
Consistent with the IFoA guidance, trustees are responsible for the following points (in relation to the work which Willis Towers Watson or scheme actuaries employed by Willis Towers Watson perform for the trustees):
- for ensuring that Willis Towers Watson and the scheme actuary are provided with the appropriate personal data that is required in order for Willis Towers Watson to deliver the services to the pension scheme;
- for ensuring that members' queries are dealt with, normally by the scheme administrator (for example, if a member wishes to access or correct his/her information);and
- for appointing the scheme actuary and Willis Towers Watson (including agreeing how we work with them and sometimes agreeing terms with us on data transfer and retention).