Privacy Policy

Data Protection Act 2018

(incorporating the European General Data Protection Regulation (GDPR))

Privacy Notice

The Trustee (Rexam Pension Trustees Limited) is committed to protecting and safeguarding your personal data, in line with the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR) as applicable to the UK by virtue of the European Union (Withdrawal Agreement) Act 2018 (the UK GDPR) (together the “Data  Protection Legislation”).

The Trustee collects and uses personal information about members and dependants of the Rexam Pension Plan (the Plan).  Personal data is held and processed in accordance with the Data Protection Legislation and the Trustee is the “data controller” for these purposes and is responsible for the confidentiality and security of the personal data it holds. The Trustee uses this personal data to calculate and pay benefits, and to administer and operate the Plan.

Members may request a copy of the information held about them (there may be a small administration charge to cover the costs of retrieving this information for you in some circumstances).  If you would like to see your information, or if you have any change of circumstance that you think the Trustee should be aware of, please write to Rexam Pension Trustees Limited, Weald Court, 101-103 Tonbridge Road, Hildenborough, Tonbridge, Kent TN11 9BF.

Information we collect about you and how we use it

 How we receive your data

We receive your data either directly from you or your employer, or from any other third party, eg your appointed Independent Financial Adviser.  Data is received either manually or electronically.

What types of personal information do we collect about you?

We hold the following personal information about you:

• Personal details such as your name, gender, marital status, date of birth, postal address, email address, telephone or mobile number and identifiers such as National Insurance number
• Employment and salary history
• Banking details such as the account number and sort code
• Personal and banking details of dependants and beneficiaries
• For Ill health cases, details in relation to your physical and mental health
• Copies of identification
• Details of your pension benefits

How do we use your information?

We will use your personal information for the purposes of administering and managing the Plan.  More information on the purposes for which we process your data can be found under Legal Bases for Processing below.

Who we share your personal data with?

We share your information with selected recipients who are involved in the running of the Plan.  From time to time, member details (including their dependants) will be shared with third parties such as actuaries, investment fund managers, advisers, insurers, administrators, other specialist external service providers and employers within the Ball group to assist with the administration and operation of the Plan, for the purpose of preventing and detecting fraud, or to provide products and services for the benefit of the Plan or members.  In certain circumstances professional advisors such as the Plan actuary and Willis Towers Watson (WTW), and insurers such as Rothesay, will also be ‘data controllers’.  You can view WTW’s privacy notice here and Rothesay’s privacy notice can be viewed here.  Member data may also be shared with Ball and its specialist professional advisers for accounting or audit purposes, or for consideration of pension strategy or employee pension provision, and Ball and/or its group companies may also be “data controllers” as a result.

Where do we store your personal data?

The information that we collect from you will be transferred to, and stored at/processed in the European Economic Area (EEA).  We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice.

We do not currently transfer your information outside of the EEA, but if in future we do, then this will only happen where we have adequate measures in place to provide appropriate safeguards, such as the Privacy Shield (where recipients comply with the US Department of Commerce’s EU-US Privacy Shield) or Model Clauses (standard clauses produced by the EU Commission). More information can be found under Transfer Mechanisms below.

How long will we keep your personal data?

Pension benefits are paid over a long period and your right to benefits payable under the Plan is based on information that may date back many years. We may decide to delete some of the data when it is no longer required for the purpose it was obtained. However, your personal information may be held for longer where:

1. We consider it is necessary to ensure the Plan pays the correct benefits
2. To deal with any queries relating to your benefits as they may arise after that time
3. It is required by law or a court order
4. It is needed to defend or pursue legal claims

Given the nature of pension schemes, we may need to keep some of your personal information for the life of the Plan and, possibly for some years after it is wound up.  After the above mentioned retention period has elapsed, we may store your information in an aggregated and anonymised format.

Legal Bases of Processing

Category of Personal Data	Processing Purpose	Legal Basis
Personal details such as name, gender, marital status, date of birth, postal/email address, telephone/mobile number and National Insurance number	To administer a member’s pension, To contact a member	Legitimate interests, Compliance with a legal obligation
Employment and salary history	To calculate benefits payable to a member	Legitimate interests, Compliance with a legal obligation
Banking details such as the account number and sort code	To make payments to a member	Legitimate interests, Compliance with a legal obligation
Personal and banking details of dependants and beneficiaries	To administer a dependant’s pension, To contact a dependant, To make payments to a dependant	Legitimate interests, Compliance with a legal obligation
For Ill health cases, details in relation to your physical and mental health	To provide medical advice	Explicit consent
Copies of identification	To verify identity	Legitimate interests, Compliance with a legal obligation
Pension benefits	To administer benefits	Legitimate interests, Compliance with a legal obligation

 

Where legitimate interests is identified above as a basis for processing, the Trustee has a legitimate interest in holding and processing the information about you for the processing purposes identified as it is needed for us to properly administer the Plan and to calculate and pay benefits.

Who do we share your personal data with?

The categories of recipients include:

Support service		Including (but not limited to)
Sponsoring employer		Rexam Limited and members of its group of companies
Plan Administrator		Currently provided by Rexam Limited
Office support	IT & Disaster Recovery (storage data providers)	Profund Solutions Ltd
	Payments	Banks, located in the UK and, in the event that you are not resident in the UK and are in receipt of a pension, the country of your residence
	External printing	Gallagher Communications
Professional advisers	Actuarial and Legal (in certain circumstances will also be ‘data controllers’)	Plan Actuary Willis Towers Watson (click to view privacy notice) Sacker & Partners (click to view privacy notice)
Insurance companies, annuity/AVC providers	To provide annuity quotes for members in payment who hold residual additional voluntary contributions and support the administration of the insurance policy purchased with Rothesay Life	Equitable Life Friends Life L&G Phoenix Life Prudential	Reassure Rothesay (click to view privacy notice) Sun Life Standard Life Zurich
Regulators and other Government organisations	To deal with complaints and resolve disputes	The Pensions Ombudsman
	To account for payments made to you	HMRC
	Existence check providers	Experian Lexis Nexis National Fraud Initiative	Faraday Office of the Public Guardian

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• comply with a legal obligation, process or request;
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent, investigate or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We may also disclose your information to third parties in the event that the Ball group sells any business or assets, in which case we may be asked to disclose your data to the prospective buyer of such business or assets, or to any new pension scheme to which your benefits may be transferred as a result of the sale.

Your rights regarding the personal information you provide to us

You have certain rights in relation to the personal information we hold about you, which we detail below.  Please note that we will require you to verify your identity before we respond to any of your requests. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please write to Rexam Pension Trustees Limited, Weald Court, 101-103 Tonbridge Road, Hildenborough, Tonbridge, Kent TN11 9BF.

Right to be informed	You have the right to be informed about the collection and use of your personal data.
Right of access	You have the right to know whether we process personal information about you, and if we do, to access information we hold about you and certain information about how we use it and who we share it with. If you require more than one copy of the information we hold about you, we may charge an administration fee. We may not provide you with certain personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person) or where another exemption applies.
Right to rectification	You have the right to access the information we hold about you and have any inaccuracies corrected. Where you request correction, please explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
Right to erasure	Also known as the “right to be forgotten”. This is not an absolute right and only applies in certain circumstances. More information can be found under Your Right to Erasure below.
Right to portability	You have the right to receive a subset of the personal data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party.
Right to object	You have the right to object to: Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling) Direct marketing Processing for purposes of scientific/historical research and statistics More information can be found under Restriction of Processing to Storage Only below. Please note we do not perform any direct marketing or profiling activities.
Rights in relation to automated decision making and profiling	The GDPR has provisions on: Automated individual decision-making (making a decision solely by automated means without any human involvement) Profiling (automated processing of personal data to evaluate certain things about an individual) Please note we do not perform automated decision making and therefore this right is not applicable.
Restriction of Processing to Storage Only	You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. More information can be found under Restriction of Processing to Storage Only below.

Your Right to Erasure

You may request that we erase the personal data we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold the personal data we hold about you;
• we are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data;
• we are processing the personal data we hold about you on the basis of our legitimate interest, and you object to such processing. Please provide us with details as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data; or
• you believe the personal data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing the data whilst we consider your request, as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (eg, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (eg for the defence of legal claims or for another’s protection).

You may request we stop processing and just store the personal data we hold about you where:

• you believe the personal data is not accurate for the period it takes for us to verify your claim;
• we wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage but not further process it;
• we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
• you have objected to us processing personal data we hold about you on the basis of our legitimate interest, and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.

You also have the right to object to our processing of data about you.

You may object where:

• we are processing the data we hold about you on the basis of our legitimate interest or public interest, and you object to such processing, although we may continue to process your data where we have a compelling legitimate grounds for doing so which overrides your interest, rights and freedoms, or for the establishment, exercise or defence of legal claims
• we are processing the data on the basis of historical/scientific research or statistics and you have a particular reason to object. Your right would not apply where we have been tasked with and it is necessary for us to undertake such processing in the public interest.

Transfer Mechanisms

• Privacy Shield: The relevant recipient will comply with the US Department of Commerce’s EU-US Privacy Shield and has certified that it adheres to the EU-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website  www.commerce.gov/tags/eu-us-privacy-shield
• Model Clauses: The personal data that we collect from you will be transferred to, stored at and/or processed by the relevant recipient under a written agreement incorporating the EU Commission’s model clauses for the transfer of personal data to third countries (the ”Model Clauses”), pursuant to Decision 2010/87/EU.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at Pensions@ball.com. This does not interfere with your right to raise a complaint with a relevant data protection supervisory authority. For the UK this is the Information Commissioner’s Office.

 

Website users

When you visit our Plan website, simple Cookies are used to help you navigate around our site and tell us how well our website is performing. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting this website and will not associate any data gathered with any personally identifying information from any source.

We collect this information for our legitimate interests to help you use our website and keep us informed about our website’s performance. For more information, please see our Cookie Policy.

Changes to our Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page and will become effective when published.  This Privacy Notice was last updated in July 2024. If you would like a paper copy of the Privacy Notice at any time, please contact us.

Contact

If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:

Rexam Pension Trustees Limited,

Weald Court, 101-103 Tonbridge Road, Hildenborough, Tonbridge, Kent TN11 9BF

Email: Pensions@ball.com

Phone from within the UK: 01732 835 100

Phone from outside the UK: +44 1732 835 100