underlying systems operated by the MaPS. Your identity will have been verified and your consent obtained by the dashboard at the time of your request. Your identity verification and consent will also be received by us. The Trustee does not use your personal data for any statistical analysis in order to facilitate the sale of any services or goods to you. The Trustee is required to advise you if automated decisions, being decisions that do not involve consideration by other individuals, occur in relation to your data. The Trustee can confirm that no automated decisions are undertaken that have significant consequences for you as the data subject in respect of the data that we hold as data controller, nor by any of the data processors with whom we share data. The lawful basis on which the Trustee processes your data is that the processing is necessary for the purposes of legitimate interests pursued by the Trustee. For these purposes legitimate interest means the Trustee’s interests as trustee of the Scheme in running the Scheme as effectively, efficiently and securely as possible. The Trustee includes within this its obligations to run the Scheme in keeping with legal requirements, which include but are not limited to trust law, pensions legislation, tax law and regulatory guidance. If you request pension information via a pensions dashboard, we are under a legal obligation to process and authenticate your request, and to make your pensions data available to you on that dashboard. In order to comply with this legal obligation, we will need to connect to the digital architecture operated by the Pensions Dashboard Programme (which is a function of MaPS) and, where a request for information is received, to share accurate, up-to-date information relating to that individual’s pension. The Trustee also has duties and powers; some of which are conferred by law and some by the governing documentation of the Scheme. Utilisation of data in order to ensure the Trustee complies with these duties and powers is also a part of its legitimate interests. All the processing of personal data that the Trustee undertakes is designed to ensure that all members receive their appropriate entitlement to a pension and other benefits. The Trustee does not consider that these legitimate interests and the legal obligation compliance requirements would cause harm or hurt to any individual in respect of whom the Trustee holds data. Any sensitive data (information on ethnicity, religious belief, trade union membership, sexual orientation or health etc.) processed by the Trustee is done so under the 'Employment, social security and social protection' provision of the Data Protection Act 2018. This provision allows the processing of sensitive data where the processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection (which includes the provision of survivors' benefits). Where the Trustee relies on such provisions, the Trustee will ensure that appropriate and adequate policies and safeguards are in place.
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