Data protection legislation and your rights

Under data protection legislation, you have the right to obtain confirmation that your data is being processed by SPPA. You also have access to your personal data and the right to object to processing in specific circumstances. Special rights also apply to the processing of children’s personal data. The following sections of our website outline your various rights and show you how to make a data protection request.

Right of access

You have the right to access personal data that we hold and we’ll normally provide your personal data within one month of your request. There’s no fee, but we will ask you to prove your identity. In some circumstances, we may require more time to locate your information. There are also certain situations where material cannot be provided, for example where disclosure may have an adverse impact upon ongoing proceedings or where the personal data of other people is also featured. In these situations, we’ll inform you of any limitations placed upon your right of access as well as providing you with information on your right to appeal to the UK Information Commissioner.

Right to erasure

You have the right to request that we cease or limit our processing of your personal data. Please note that this right is unlikely to apply where processing remains necessary in relation to the purposes for which your data was collected.

Right to rectification

You have the right to request that we correct or amend our records if you have reason to think we’ve made a mistake in recording or processing your personal data, for example if it’s inaccurate or incomplete.

Contacting our data protection officer

If you’re unhappy with how your personal information is being processed, or you wish to make a personal data request, please contact our data protection officer at:

Scottish Public Pensions Agency
7 Tweedside Park
Galashiels
TD1 3TE

Tel: 01896 892 469

If after dealing with our data protection officer, you’re still unhappy, you have the right to complain to the Information Commissioner's Office at the address below:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113
Email: casework@ico.org.uk
https://ico.org.uk/global/contact-us

Our privacy policy

The Scottish Public Pensions Agency is an executive Agency of the Scottish Government. On the behalf of the Scottish Ministers, we undertake our role as a pension scheme administrator in accordance to the Pensions Act 1995, The Public Services Pension Act 2013 and The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013. The following information describes the way we collect and process your data in different circumstances.

Pension scheme members

We collect and process personal data to allow us to administer the pensions, injury benefits and premature retirement compensation arrangements for the devolved public service schemes in Scotland. These are set out in statutory regulations made by the Scottish Ministers, with the consent (as required) of HM Treasury.

The legal basis for this processing is detailed within our statutory framework.

For the purposes of scheme administration we collect:

Data collected

What this information is used for

Who has access to this information

Title

Used to maintain an accurate record. It can be used to ensure that correspondence is appropriately addressed. SPPA Staff

Forename

Used to identify who the scheme member/pensioner is and to ensure that correspondence is appropriately addressed. SPPA Staff

Middle Name

Used to identify who the scheme member/pensioner is and to ensure that correspondence is appropriately addressed. SPPA Staff

Surname

Used to identify who the scheme member/pensioner is and to ensure that correspondence is appropriately addressed. SPPA Staff

Address

Used to identify who the scheme member/pensioner is and to ensure that correspondence is appropriately addressed. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

Postcode

Used to identify who the scheme member/pensioner is and to ensure that correspondence is appropriately addressed. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

Phone/Mobile Number

Used for the purpose of of contacting the scheme member/pensioner. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

Email Address

Used for the purpose of of contacting the scheme member/pensioner. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

National Insurance Number

Used to fulfil statutory requirements. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

Date of Birth

This information is gathered to satisfy certain legal obligations in relation to scheme regulations. Used with other data to identify who the scheme member/pensioner is. SPPA Staff

Gender

This information is gathered to satisfy certain legal obligations in relation to scheme regulations. SPPA Staff

Marital Status

Used to maintain an accurate record. SPPA Staff

Superannuation Number

Used as a unique identifier. SPPA Staff

Pay Reference

Used as a unique identifier. SPPA Staff

Rank (Police Scheme)

Used for the purpose of calculating entitlements. SPPA Staff

Employer's Pensionable Pay

Used to maintain an accurate record. SPPA Staff

Employee's Pensionable Pay

For the purpose of calculating entitlements. SPPA Staff

Employee Contributions

For the purpose of calculating entitlements. SPPA Staff

Employer Contributions

For the purpose of calculating entitlements. SPPA Staff

Employment History

For the purpose of calculating entitlements. SPPA Staff

Health Reports

Used to maintain an accurate record and to inform injury benefit or ill health decisions. SPPA Staff

Bank Details

Used to pay pension. SPPA Staff

SPPA processes personal data for the purposes of:

  • Maintaining records to support the operation of the schemes
  • Calculating, authorising and paying pensions, other benefits and any other sums due on retirement and thereafter under schemes' regulations including injury benefits (for NHS, Police and Fire schemes only)
  • Calculating, authorising and paying pensions to spouses/partners and dependents on the death of a member/pensioner
  • Maintaining systems to support the prompt and accurate payment of sums due
  • Processing elections made under the regulations by members
  • Calculating and paying refunds of contributions and providing services to support the purchasing of additional pension
  • Calculating and paying the transfer of pension rights to and from other pension providers
  • Providing information to members and their employers, to their agents and to UK Government Departments such as the Department for Work and Pensions and HMRC
  • Maintaining facilities for Additional Voluntary Contributions for scheme members, as laid down in the schemes' regulations
  • Collecting sums due to the Scottish Ministers under the regulations (not Police and Fire Schemes)
  • Maintaining accounts of income and expenditure under the regulations (not Police and Fire Schemes)
  • Preparing budget estimates of income and expenditure and monitoring actual payments against estimates (not Police and Fire Schemes)
  • Providing accurate information to other parts of the Scottish Government and to the schemes' actuaries for accounting and valuation purposes
  • Liaising with HM Treasury, other UK Departments and bodies regulating and administering public service pensions
  • Providing services in support of the governance framework created by the Public Service Pension Act 2013 for the pension schemes for which the Agency has administrative responsibility
  • Providing Cash Equivalent Transfer Values for divorce purposes and the implementation of Pension Sharing on Divorce orders for which income is generated.

All information collected for the purposes of scheme administration is stored and processed on our secure servers held within the European Economic Area.

Website visitors

Analytics

When you visit our website or log in to your SPPA account, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We collect information about:

  • the pages you visit and how long you spend on each page
  • how you got to SPPA's websites
  • what you click on while you're visiting SPPA's websites.

The information we get from Google Analytics doesn’t allow us to identify anyone individually. For example, we never receive your name or address. We don’t make, and don’t allow Google to make, any attempt to find out the identities of people who visit our website.

If you like, you can opt out of Google Analytics at any time.

Cookies

This site places small files, known as 'cookies', onto your computer to collect information about how you browse. These cookies aren't used to identify you personally. You’ll normally receive a message from the site before we store a cookie on your computer.

Find out more about how to manage cookies.

If we need to collect personally identifiable information through our website, we’ll make it clear to you that we’re collecting personal information and we’ll also explain what we intend to do with that information.

Online Services

Secure online services are currently available for our NHS and Teachers members and pensioners. In order to register, users will need to provide the following information that allows us to identify you with the data we hold.

  • Email address
  • Surname
  • Date of Birth
  • National Insurance Number
  • Superannuation / GTC or Pension Payroll reference number
  • Password

Contact us

When online, we encourage our scheme members and pensioners to contact us through our secure member area.

For people who aren’t scheme members, we provide a General Enquiries contact form through which we collect a name and email address. We ask that the General Enquiries form is not used to convey additional personal information.

Survey respondents

We use a third party provider, Survey Monkey, to host our online Customer Service Survey, which we use to monitor our levels of customer satisfaction. We apply survey settings that allow us to collect survey data securely and anonymously.

Participation with our Customer Service Survey is completely voluntary. We don’t ask for any personal information and don’t encourage people to provide personal data through free text boxes.

SPPA's established complaints procedure should be used to register dissatisfaction with any of our services. Our procedures comply with the Scottish Public Services Ombudsman's guidance on a model complaints handling procedure.

Phoning SPPA

The Telephony System used by SPPA can record all of the calls we receive, with recording data stored on SPPA's internal servers.

The Customer Contact Team within the Customer Services Department is the only business area within SPPA that uses this call recording functionality.

Outbound calls made by SPPA staff or internal calls between SPPA staff are not recorded.

Calls where the caller provides details of a payment card for the purpose of making a payment to SPPA will only be recorded in-part to comply with Payment Card Industry Security Standards.

The purpose of call recording is to provide an exact record of the call which can:

  • help identify staff training needs and help support training of new and existing staff
  • help improve staff performance
  • help protect staff from abusive or nuisance calls.

Recordings are selected for review through random sampling of individual staff member's calls.

SPPA staff can draw a particular recording to a team leader's attention if they feel it is useful for training, or is valuable for evidence purposes in the event of persistent/unacceptable caller behaviour.

Occasionally, team leaders will listen to a sample of call recordings to ensure that they are all reviewing recordings to the same standard.

Every caller is informed that the call is recorded and why, before the conversation begins. This will be done by a pre-recorded message, in the SPPA welcome message on the Liberty phone system, before connection is made to the SPPA member of staff.

A caller may request that their call is not recorded. In this situation, the caller will normally be advised to contact SPPA either in writing or by email. In exceptional circumstances a caller who does not wish to be recorded will be transferred to a non-recorded phone line. This decision will be made by a manager, if they judge that not doing so could cause distress to the caller.

Recordings will normally be retained for a maximum of 3 months and then automatically deleted.

Some recordings may be retained for longer than three months for the following reasons:

  • because they’ve been identified by SPPA managers as valuable for staff training. In this case, we’ll seek permission from the member of staff to use the recording to train others and the recording will be retained until it’s no longer useful for this purpose. We’ll review retained training calls every six months to see if they’re still useful for training and delete any recordings that are deemed to be no longer useful.
  • if they’re identified as evidence for the record keeping requirements of SPPA's procedure for dealing with unacceptable behaviour towards staff or unreasonably persistent complainants.

Visitors to our office

SPPA uses closed-circuit television (CCTV) images to reduce crime and to monitor our building in order to provide a safe and secure environment for staff and visitors, and prevent the loss or damage to SPPA property and assets.

CCTV captures images of people entering and leaving the building, including staff, however monitoring of staff is incidental to the above purpose and not the main intent of the system.

SPPA is responsible for all CCTV operated within its premises and is the data controller in terms of our obligations under Data Protection legislation.

Individuals have the right to request CCTV images relating to themselves under the subject access provisions of Data Protection legislation. SPPA will adhere to the subject access request (SAR) procedure and statutory timescale when responding to these requests. To make a request contact SPPA Facilities on 01896 893122 or by email at SPPAFacilities@gov.scot.

Authorised personnel with an enforcement function, such as Police Scotland, can make requests to access CCTV images for the purposes of the prevention and detection of crime. Procedures outlined by Data Protection legislation must be adhered to when responding to these requests.

CCTV images are retained for 30 days after which time they are deleted from the system. Images may be retained for longer periods if required for disclosure.

SPPA Employees

SPPA staff are civil servants in the employment of the Scottish Government.

eHR is the system the Scottish Government uses to hold information about staff (which can include contractors and secondees). SPPA's HR Team can access this system in order to maintain employment records (information held on eHR). The table below sets out what this information is, what we use it for and who can see it.

Information is held for the purposes of:

  • Maintaining an accurate staff record and to ensure previous records are associated with current records.
  • Fulfilling statutory requirements in connection with tax and National Insurance.
  • Satisfying certain legal obligations in relation to minimum wage and young workers.
  • Assisting in the development of policies that are free from bias and discrimination.
  • Contacting staff or a named individual in case of an emergency.
  • Recording if staff have elected to waive the 48-hour requirement of the working time directive.
  • Recording if staff have requested the Scottish Government to supply child care vouchers.
  • Administrating pay.
  • Satisfying eligibility for employment and diversity monitoring.
  • Administrating staff assignments.
  • Staff welfare, health and safety.

Data Collected

What this information is used for

Who has access to this information?

Name

The first name and last name are used to identify individuals. Scottish Government staff

Title

This information is used to maintain an accurate staff record. It can be used to ensure that system generated correspondence is appropriately addressed. Scottish Government staff

Prefix

This refers to the prefix of a surname i.e. von, van, le etc. This information can also be entered in the surname field. This is not a mandatory field and can be left blank. Scottish Government staff

Middle Name

This information is used to maintain an accurate staff record. This is not a mandatory field and can be left blank. HR only, but Scottish Government staff can see the initial

Suffix

This refers to the suffix of a surname i.e. Snr, Jnr, III etc. This information can also be entered in the surname field. This is not a mandatory field and can be left blank. Scottish Government staff

Preferred Name

This information is used to maintain an accurate staff record. It can be used to ensure that system generated correspondence is appropriately addressed. This is not a mandatory field and can be left blank. Scottish Government staff

Previous Last Name

This information is used to maintain an accurate staff record and to ensure previous records are associated with current records. This is not a mandatory field and can be left blank. HR staff only

Other/NI Number

NI number is mandatory* data required to fulfil statutory requirements in connection with tax and National Insurance.

*Only for staff paid through the SG payrolls.

HR staff only

Date of Birth

This information is gathered to satisfy certain legal obligations in relation to minimum wage and young workers. It is also used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. HR staff only

Marital Status

This information is used to maintain an accurate staff record. This field is not mandatory and can be left blank. HR staff only

Gender

This information is used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. Employer needs to see legal gender recognition certificate. HR staff only

Address

A primary and/or emergency contact address is useful should it be necessary to make contact in the case of an emergency. HR staff only

Attachments

This is a standard part of the database package and it is not anticipated that you will attach any information. This is not mandatory and can be left blank. HR staff only

Emergency Contact Details

This information may be used in the event of an emergency. This field is not mandatory and can be left blank. HR staff only

Date Relationship Started

This feature is supplied as part of the standard Oracle system and it is not mandatory. However, if the date is left blank it defaults to today's date - we are unable to change this feature. If individual does not wish to enter the actual start date of relationship, simply enter the date as '01-Jan-1901'. This is the date that will appear and it is obvious that the date is notional. HR staff only

Sexual Orientation

This non mandatory information is used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. The categories used are supplied by the Cabinet Office so employer can make accurate comparisons and returns to the Cabinet Office in the same format as other Government departments. They are also the categories recommended by LGB organisations. Only the Diversity Team and very small number of HR staff who require it

Religion/Religious Belief

This information is used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. The categories used are supplied by the Cabinet Office so employer can make accurate comparisons and returns to the Cabinet Office in the same format as other Government departments. They are also the categories recommended by some BME organisations. Only the Diversity Team and very small number of HR staff who require it

Ethnic Origin

This information is used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. The categories used are supplied by the Cabinet Office so employer can make accurate comparisons and returns to the Cabinet Office in the same format as other Government departments. They are also the categories recommended by some BME organisations. Only the Diversity Team and very small number of HR staff who require it

Working Time Waiver

This records the fact that you have elected to waive the 48-hour requirement of the working time directive. Only the Diversity Team and very small number of HR staff who require it

Child Care Vouchers

This records the fact that employer has requested the S to supply child care vouchers. HR staff only

Bank Details

This data is used to ensure pay goes into the correct account. HR & Finance staff only

Employee Pay Reference Number

This is used to identify who the staff member is and for the administration of pay. Scottish Government staff

Nationality

Eligibility for employment and diversity monitoring. HR staff only

Email Address (office)

Administration of staff assignments. Scottish Government staff

Job Title

Administration of staff assignments. Scottish Government staff

Disability

This information is used for monitoring purposes and to assist in the development of policies that are free from bias and discrimination. HR staff only

Room/Area

Administration of staff assignments. Scottish Government staff

Location/Building Name

Administration of staff assignments. Scottish Government staff

Work Address

Administration of staff assignments. Scottish Government staff

Cost Centre

Administration of staff assignments. Scottish Government staff

Date of Entry to the Scottish Government

Administration of staff assignments and pensions. HR staff only

Current SG Service Start Date

Administration of staff assignments and pensions. HR staff only

Civil Service Entry Date

Administration of staff assignments and pensions. HR staff only

Years of Service

Administration of staff assignments, annual leave entitlement and pensions. HR staff only

Assignment Details inc. dates

Administration of staff assignments. HR staff and Manager

Grade

Administration of staff assignments and pay. Scottish Government staff

Line Manager

Administration of staff assignments. Scottish Government staff

Annual Leave Balance

Administration of staff assignments. HR staff and Manager

Additional Responsibilities

Administration of staff assignments. Scottish Government staff

Details of Allowances

Administration of staff assignments and pay. HR staff and Manager

TRS Details

Administration of staff assignments and pay. HR staff and Manager

Temp Promotion Details

Administration of staff assignments and pay. HR staff and Manager

Absence Type

Administration of staff assignments and pay. HR staff and Manager

Absence Start and End Dates

Administration of staff assignments and pay. HR staff and Manager

Absence Sickness Reason

Administration of staff assignments, staff welfare, health and safety and pay. Manager if staff member allows this, or HR only

Total Absences

Administration of staff assignments, staff welfare, health and safety and pay. HR staff and Manager

Total Days

Administration of staff assignments and pay. HR staff and Manager

Average Days per Year

Administration of staff assignments and pay. HR staff and Manager

Working Pattern

Administration of staff assignments and pay. HR staff and Manager

MyCSP

Staff details will be provided to MyCSP who are the administrators of the Civil Service Pension Scheme, of which the Scottish Government is a member organisation. Employees will be auto-enrolled into the pension scheme and details provided to MyCSP will be your name, date of birth, National Insurance number and salary. Bank details will not be passed to MyCSP at this time.

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