Privacy Policy and Investment Statement

Privacy Policy

The Trustees of the Airbus UK Pension Scheme is committed to protecting the rights of individuals in line with the UK General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

Airbus UK Pension Scheme Trustees Limited is the trustee (“the Trustee”) of the Airbus UK Pension Scheme (“the Scheme”). For legal purposes, the Trustee is known as the “data 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 data controllers which include Legal & General and Airbus.

The protection of your privacy and Personal Data is an important concern to which we pay special attention throughout our business processes. 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.

What is Personal Data?

Personal data is information that can be used to identify a person either directly or indirectly. It includes information such as name, contact details, identification numbers, financial data, location data or online identifiers.

Special category of Personal Data is any Personal Data which relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, sex life or sexual orientation and includes genetic data, and biometric data where processed to uniquely identify an individual (hereinafter referred as : ‘Sensive Personal Data’).

Which sources and what Personal Data do we use?

Depending on the circumstances and the stage of your membership, we may hold some or all of the following information about you:

Identification data: name, first name, date of birth, contact details (job title and function, professional phone number, email, employer name), national insurance number, gender, details of your race/ethnicity, details of sexual orientation, details of religious/philosophical political beliefs, details of membership of trade union
Economic and Financial data: details of your bank account (to pay benefits), details of your pay and any associated benefits, bonuses etc
Health data: medical and other details about your health
Dependants and Beneficiaries: details about your dependants and/or beneficiaries

We collect this Personal Data cumulatively:

directly from you by completing a form, by entering contact details,
indirectly from your organisation you are working for.

How we use your your Personal Data?

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. We also keep the above information in order to allow us to comply with our obligations towards members under the Scheme governing documents, as well as under relevant legislation. We will not collect any personal data from you that we do not need.

Personal data relating to the Scheme is held on paper and on computer systems. As the “data controller”, the Trustee must process this information fairly and lawfully.

As part of running the Scheme, we may also need to hold and process sensitive personal data about you and/or your dependents and beneficiaries. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

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 (unless opted out).

What is the legal basis for processing of your Personal Data?

We process your Personal Data in accordance with the provisions set out in the applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data are:

Necessary for the compliance with legal obligations to which Airbus, the Scheme, or the Trustee are subject.
Necessary to perform the contract between you and Airbus.
Necessary for the purpose of the legitimate interests pursued by Airbus, by that the Trustee considers that we have a legitimate interest in ensuring that employees are properly enrolled into a pension scheme and that pension scheme is properly administered.

Who will receive your Personal Data?

Some of your personal information will be shared with:

Pension administrators
Tracing agents
Governmental authorities (such as the HM Revenue and Customs)
Independent Financial Advisers
New pension schemes (as appropriate)
Accountants and actuaries

Additionally we may disclose your Personal Data to the following recipient(s) on a strict need to know basis and for the Purposes as outlined in this Privacy Notice:

Other authorised third parties in connection with a reorganisation, merger or sale of Airbus businesses, and/or assets;
Law enforcement or any relevant authorities where necessary to comply with applicable law.

How long will your Personal Data be stored?

We process and store your Personal Data as long as it is required to meet our contractual and statutory obligations. The retention period of your Personal Data is determined by applicable Laws and Regulations and/or by our procedures or processes adopted in accordance with applicable Laws and Regulations.

What about the security of your Personal Data?

We use technical and organisational security measures in order to protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons.

Our security procedures are continually enhanced as new technology becomes available by relevant Airbus departments

What are your rights?

At any time, you may exercise your data protection rights as listed below by contacting us at dataprotection@airbus.com, or you can write to HO Group Schemes & Benefits UK, Gunnels Wood Road, Stevenage SG1 2AS. We may ask you to validate your identity by enclosing a copy of any identity document.

Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your personal data is being processed by Airbus and if so, what specific personal data is being processed.
Right to correct personal data: You have the right to change any inaccurate personal data concerning you.
Right to be forgotten: In some cases, for instance, when the personal data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your personal data to be erased.
Right to restrict the processing of your data: You have the right to restrict the processing of your personal data by Airbus, for instance when the processing is unlawful and you oppose the erasure of your personal data. In such cases, your personal data will only be processed with your consent or for the exercise or defence of legal claims.
Right to data portability: Under some circumstances provided by law, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and/or transmit those personal data to another data controller.
Right to object: In some cases required by law, you may ask us to stop processing your personal data.
Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent. However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services.