Privacy Policy and Investment Statement
Our committment
The Trustees of the Airbus UK Pension Scheme is committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU 2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred to as : ‘GDPR’) as well as each applicable national Personal Data protection laws and regulations (collectively referred as “Data Protection Laws and Regulations”).
Privacy Policy - Who are we?
Airbus UK Pension Trustee is the trustee (the “Trustee”) of the Airbus UK Pension Scheme (the “Scheme”). As the Trustee of the Scheme, we hold certain personal information (known as “personal data”) about scheme members and, where applicable, their dependants and beneficiaries. Most of the personal data held and processed by the Trustee in running the Scheme will be personal data. For legal purposes, the Trustee is known as the “Controller”, as we decide the purposes for and the means by which the personal data we hold is processed. The Scheme also works with joint Controllers which include Legal & General and Airbus.
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What is Personal Data?
What information we collect about you Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:
- ● your name and date of birth, your address
- ● your national insurance number
- ● your gender
- ● your family / marital status
- ● details of your bank account (to enable us to pay benefits)
- ● details about your dependants and/or beneficiaries
- ● emergency contact information
- ● medical and other details about your health
- ● details of your pay and any associated benefits, bonuses etc
- ● your email address and telephone number
- ● details of your race / ethnicity
- ● details of sexual orientation
- ● details of religious / philosophical political beliefs
- ● details of membership of trade union
- ● your career history
- ● your hire date
- ● date of death
- ● details of any absence
- ● details of your assets
- ● details of your investments
- ● a copy of your passport and/ or ID card
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How do we collect your personal data ?
We will collect your personal information when you, any of your dependants or relatives or your employer contact us by phone, email or post. We will also obtain your information where 1 this is provided through any other discussions or correspondence that you, any of your dependants or relatives or your employer may have with us. We may also collect personal information about you from other third parties, including tracing agencies, HMRC, the DWP and/or other regulatory bodies, and from public sources. We also receive information from members about their proposed beneficiaries, who may be eligible to receive benefits on the member's death. We assume that you have the consent of those individuals to provide us with this information and you may wish to share this privacy notice with them. We will not provide a copy of this notice to those individuals as to do so is likely to seriously impair our ability to properly discharge our responsibilities in respect of such benefits.
How we use that information ?
The Trustee has a legitimate interest in holding and processing the above information about you as it is needed for us to properly administer the Scheme and to calculate and pay benefits, including making payments to beneficiaries. We also keep the above information in order to ensure that the Scheme is appropriately funded, to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation. We may also use it to improve the day-to-day running and operation of the Scheme. We will not collect any personal data from you that we do not need, and we will only use it for the purpose(s) for which it was collected (unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose). If we need to use your personal information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. As part of running the Scheme, we may also need to hold and process particularly sensitive information about you and/or your dependent(s) and beneficiaries (known as “special category data”), for example in situations involving ill-health early retirement or death benefits. Under the legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation and political affiliations are regarded as “special category data”. We will in most circumstances process special category data as necessary for the establishment, exercise or defence of legal claims to benefits or in the performance of our legal obligations in connection with employment, social security and social protection (as allowed by legislation). Where we require to rely on your consent for processing special category data, we will take appropriate steps to obtain your consent, which may be withdrawn by you ta any time. Personal data may also be used for automated decision making.
This may include:
● Eligibility for auto enrolment
● Eligibility for SMART (salary sacrifice)
● Default investment switching.
This is based on a combination of factors such as age and target retirement date. This will be used to automatically switch your investments if you are in a lifestyle fund
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Who we share it with?
We are not allowed to disclose personal data about you to other parties except:
● when required for contractual or legal reasons or other specifically identified purposes; or
● where you have given your consent. As the Trustee needs help from various advisers to properly administer the Scheme, we share personal data with the following:
● your current, past or future employer which may include group companies which are based outside the UK and EEA. Where data is sent outside the UK and EEA, appropriate safeguards are put in place to ensure that your data is kept secure. If your data is being transferred outside of the UK and EEA (for example if you are working in a different country), your employer will be responsible for providing you with information about this and the safeguards that will be in place
● your past pension schemes/providers to query any information that is held
● the Scheme’s professional advisers, including the Scheme actuary, administrator, auditor, medical advisers, investment adviser and lawyers
● the third parties who are responsible for the day-to-day administration of the Scheme on behalf of the Trustee including tracing agents and existence checkers
● local or foreign regulators, governments, law enforcement and tax authorities including HM Revenue & Customs and other legal/statutory bodies (such as the Pensions Ombudsman, the Pensions Regulator and the UK Courts) the advisers and printers who help us prepare various communications we send to you, such as the annual benefit statement
● local and foreign courts, tribunals and arbitrators or other judicial committees, if applicable
● our appointed insurance company or companies for the purposes of life insurance and additional voluntary contributions (including, in certain circumstances, insurance companies’ advisers)
● depending upon how we pay pensions, the personal data we have to supply in order to effect a BACS transfer (the Bankers' Automated Clearing Service) or CHAPS (the Clearing House Automated Payment System) in the UK and/or a payment via HSBC when pensions are being paid overseas
● persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change to the Scheme or the Scheme's sponsoring employer (including any potential or actual purchaser of the sponsoring employer or their parent companies and that purchaser's advisers) In some circumstances we are joint controllers with the Scheme actuary (WTW), L&G (who provide auto-enrolment services to the Trustee), the legal advisers to the Trustee (Sackers/CMS) - who will process personal data to comply with their professional duties as advisers to the Trustee - and/or the Scheme’s principal and participating employers. The Scheme’s principal and participating employers hold personal data to comply with their legal obligations as sponsoring employers of the Scheme. They have a legitimate interest in the Scheme being run in a cost-effective way and may have an interest in offering certain options 3 to members. The Trustee will share information with the Scheme’s principal and participating employers and their auditors and advisers for this purpose.
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How long we keep personal data for ?
We must keep all personal data safe and only hold it for as long as necessary to carry out the relevant activities or services listed above. To meet the requirements of both UK tax and pensions law, we must keep certain personal data (for example, details about the date a member joins the Scheme, their name and address, and details of benefits paid) for a minimum of 6 years. But, given the nature of pension schemes, the Trustee may be required to keep some of your personal information for the rest of your life. However, we review the personal data held in relation to the Scheme on a regular basis in accordance with our data retention schedule. When determining how long we will hold your personal data for, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If we conclude that certain personal data is no longer needed, that personal data will generally be securely destroyed. The Scheme actuary will hold on to your personal data for a maximum of 10 years after the termination of their contract with us. L&G for certain research and statistical activities, holds minimised personal data indefinitely. This is to protect themselves against any subsequent legal claims.
Transfers of data to outside of the UK ?
As noted above in the context of data being shared with group companies located elsewhere, we may transfer, store, or process your personal data outside the UK. If we do, we will take reasonable steps to ensure that your information is treated securely and in accordance with this notice, including making sure that any personal data we transfer meets the special requirements for international transfers under data protection law. This may include us entering into data transfer agreements based on the model clauses approved under current data protection law.
What about the security of your Data via Internet submission?
Unfortunately, the transmission of information via the internet is not always entirely secure. Although we will do our best to protect your personal information, we cannot guarantee the safety of your information transmitted via email; any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorised access.
Mitigations implemented if outside of office work applies?
The processing of personal data by the Trustees may be carried out in a virtual environment, particularly where significant amounts of work are completed by individuals working at home. Such work may involve the remote accessing of personal data and video calls on which 4 personal data is shared. The Trustee has arrangements in place to only use methods and technologies that they consider to be secure for this purpose.
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Your rights
You have the right to see personal data that is held about you and a right to have a copy provided to you, or someone else on your behalf, in a machine readable (namely, digital) format. If at any point you believe that the personal data we hold about you is inaccurate/wrong, you can ask to have it corrected. You can require the Trustee to restrict/limit the processing of your personal data in certain circumstances, for example, whilst a complaint about its accuracy is being resolved. You can object to your personal data being processed, although the Trustee can override this objection in specific instances where they have a legitimate interest in processing that information. Where you have given us your consent to processing your personal data, you can withdraw that consent at any time by notifying us (see “Who to contact” below). It may be possible for the Trustee to continue processing your personal data where such continued processing is considered justified in the circumstances. You can request that your personal data is deleted altogether although the Trustee can override this request in certain circumstances. You should be aware that taking any of the above steps could impact on our ability to make payment of your benefits and/or your participation in the Scheme and/or our ability to answering questions relating to your benefits. You can request to obtain and reuse your personal data for your own purposes across different services. Information will generally be provided to you free of charge, although the Trustee can charge a reasonable fee in certain circumstances. You also have the right to make a data protection complaint directly to the Trustee if you consider that there has been an infringement of UK data protection legislation in connection with your personal data. You also have the right to complain to the Information Commissioner’s Office (ICO) at any time. Further details of how to make a data protection complaint are set out below.
Who to contact about your personal data ?
If you wish to:
● see your personal data or to exercise any of the rights mentioned above; or
● make a complaint about how we have handled your personal data (including a data protection complaint — see below),
Please contact the Scheme Secretary or HO UK Group Schemes & Benefits by emailing ukpensions@airbus.com Making a data protection complaint to the Trustee If you consider that the Trustee has failed to comply with its obligations under UK data protection legislation in connection with your personal data, you have the right to make a data protection complaint directly to the Trustee. By way of example, this could include a complaint about the way the Trustee has collected or secured your personal information, or how it has responded to a data subject access request. Data protection complaints can be made in any form (including by email, telephone, post, or in person) and should be directed to the Scheme Secretary or HO UK Group Schemes & Benefits by emailing ukpensions@airbus.com.
The Trustee’s procedure for handling data protection complaints is set out in Section 11 of the Scheme’s Internal Dispute Resolution Procedure. Data protection complaints will be acknowledged within 30 days and responded to without undue delay. Making a complaint to the Information Commissioner’s Office You also have the right to complain to the ICO at any time if you believe that the Trustee is processing your personal data in a way which is inconsistent with the law.
You do not need to raise a complaint with the Trustee first, although the ICO may suggest that you do so. The ICO can be contacted at: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Phone: 0303 123 1113 Website: ico.org.uk Updates to this notice
This notice is the latest version as of April 2026. This notice will be updated from time to time.