WESTERN POWER PENSION SCHEME

PRIVACY NOTICE

The Trustee holds and processes personal data about you and other beneficiaries in the Scheme to be able to run the Scheme properly. In doing so, we comply with relevant data protection legislation.

What we do with your data

As a data controller, the Trustee collects and processes your personal data for the purposes of complying with its legal duties to administer the Scheme. Personal data is any information which could be used to identify you as a living individual.

Whilst much of the data we hold has been provided by you, we also hold and process data provided by your employer within the Western Power Distribution Group (“WPD”), any scheme you may have transferred your pension benefits into this Scheme from, HMRC, the DWP and regulatory bodies and by tracing organisations.

You may also need to provide us with personal data relating to other people (for example, your spouse, civil partner, partner or dependants). When you do so, you will need to check with them that they are happy for you to share their personal data with us and for us to use it in accordance with this privacy notice.

The data we hold is to help the Trustee to pay your pension benefits and the data includes your name, address, salary, years of service with the Scheme, date of birth, NI number and contact details.

We may also hold special categories or “sensitive” data about you in order to administer the Scheme for example, data relating to your health or your marital status. We will in most circumstances process this data in the performance of our legal obligations in connection with employment, social security and social protection (as allowed by legislation). We may also, typically when considering claims under the Scheme’s Internal Dispute Resolution Procedure, process any sensitive data for the purposes of establishing, exercising or defending legal claims. If there are occasions where we are relying on your consent to process your sensitive data, you can withdraw it at any time by contacting the Trustee via the Scheme’s administrators; see “Contact Details” on the next page.

Who else processes your data?

We share your personal data with other third parties involved in running the Scheme, for example, with the WPD Pensions Team and Capita who are the Scheme administrators, Damien Kelson at Aon as the Scheme Actuary (Aon have also provided some additional information at the end of this notice) and the WPD employer responsible for the Scheme. An illustrative data flow document is set out at the end of this privacy notice.

In some circumstances we are joint controllers with the Aon (the Scheme Actuary who have also provided some additional information at the end of this notice), CMS Cameron McKenna Nabarro Olswang LLP (the legal advisers who may process your data to comply with their professional duties as advisers to the Trustee) and your Employer if you are still employed by a WPD Group company. Your Employer holds your data to comply with its legal obligations as the sponsoring employer of the Scheme. Your Employer has a legitimate interest in ensuring your pension benefits are provided to you and that the Scheme being run in a cost effective way. The Trustee may share information with your Employer and its auditors and advisers for this purpose.

Your Employer and other advisers may from time to time transfer data to other countries, including outside the European Economic Area. Where such transfers are made, the parties involved will ensure adequate safeguards are in place.

Storage of your personal data

Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information which may go back many years. Our policy is therefore to retain information relating to you until your membership of the Scheme ends.

Once your membership ends, we may decide to delete some of the data held in relation to you after 6 years. However, information will be held for longer where we consider it appropriate in order to ensure the Scheme pays the correct benefits and to deal with any queries relating to your benefits which may arise after that time.

Your rights

You have the right to access your personal data and, require that we rectify any errors in the data that we hold, or request that we erase your personal data. In some circumstances, you can also require that we restrict the way we process your personal data, object to its processing or request a copy of your personal data for the purposes of transmitting elsewhere. Where we have requested and obtained your consent to process particular information, you may withdraw that consent at any time. However if we do not hold all the data we need to administer your benefits, we may not be able to pay out the benefits you are entitled to.

Contact details

If you have any questions about this Notice or any about how your personal data is held, please contact the Scheme’s administrators in relation to membership of the 1993 Section at Capita, Hartshead House, 2 Cutlers Gate, Sheffield, S4 7TL, Tel: 0114 2737331 or the WPD Pensions Team as the administrators in relation to membership of the 2010 Section:

Western Power Distribution

Pensions Team

Electricity House

Elliott Road

Plymouth

PL4 0SD

Tel: 01752 502264

wpdpensions@westernpower.co.uk

They will review your questions and pass these on to the relevant data controllers where appropriate.

What if you have a complaint?

To make a complaint about how the Trustee has handled your information, contact us as set out above.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner's Office. Its contact details are:

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone number: 0303 123 1113 or 01625 545 745

Financial data flows with:

Fund Managers - BlackRock

Covenant Assessor - RSM

Office of National Statistics (annual surveys)

Aon Hewitt Limited "QUICK READ" PRIVACY NOTICE

Aon Hewitt Limited (and, where appointed, the Scheme Actuary - together "Aon") has been appointed to provide pensions advisory and calculation services that relate to your membership of the pension scheme. In doing so Aon will use personal information about you, such as your name and contact details, information about your pension contributions, age of retirement, and in some limited circumstances information about your health (where this impacts your retirement age) in order to be able to provide these services. The purposes for which Aon use personal information will include management of the Scheme and your membership within it, funding the Scheme (i.e. helping to ensure that the funds within the pension scheme are sufficient to cover the members who are party to it), liability management (that is to say providing advice on the different ways benefits could be determined, and drawn, from the pension scheme), scheme actuary duties (which include assessing individuals who are members of the pension scheme and assessing how the make-up of the membership may affect the amounts payable and when they become payable so as to manage the pension scheme appropriately), regulatory compliance, process and service improvement and benchmarking.

Aon may pass your personal information to third parties such as financial advisors and benefits providers, insurers, our affiliates and service providers and to certain regulatory bodies where legally required to do so. Depending on the circumstances, this may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.

More detail about Aon’s use of your personal information is set out in our full Privacy Notice. Aon recommends that you review this notice which is available online at http://www.aon.com/unitedkingdom/products-and-services/human-capital-consulting/aon-hewitt-actuarial-services-privacy-statement.jsp or you can request a copy by contacting contact us, including reference to the Scheme at: Data Protection Officer, Aon Hewitt Limited (Retirement and Investment UK), PO Box 730, Redhill, RH1 9FH.

May 2018