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General Data Protection Regulation


The European General Data Protection Regulation (GDPR) will apply directly in the UK from 25 May 2018, and will make some fundamental changes to the current requirements surrounding data protection. Key areas of change include:

  • The information which must be contained in privacy notices (notices stating the use to which an individual’s personal data may be put);
  • What must be done when seeking individuals’ consent to the processing of their data;
  • Requirements around data subject access requests (when individuals can demand to see the personal data being held about them); and
  • Accountability and the sanctions for failure to comply.

Complying with GDPR is expected to be obligatory, regardless of the outcome of the UK’s Brexit negotiations.

There are four key areas for trustees of pension funds to consider

  • Updating privacy notices;
  • Record keeping and accountability;
  • Dealing with third party processors; and
  • Preparing for breaches.

Clearly for most SSAS schemes the third party will of course be the Scheme Administrator who will need to comply on behalf of the trustees. It may no longer be necessary to register schemes with the ICO.

Like many organisations we are working through the detail and will be advising member trustees of any duties that may fall to them.

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