This segment sets out how BAE Systems (as your current or former employer) as well as the trustees of the BAE Systems defined benefit pension schemes use your personal information to administer and manage your membership of the pension scheme.

This notice should be read in conjunction with the Overview. For information on how your personal information is used to administer and manage your membership of the BAE Systems Retirement Savings Plan, the defined contribution pension scheme, please contact Scottish Widows, the administrator of the Mercer Master Trust). Additional information regarding the BAE Systems pension schemes, including relevant contact details, can also be accessed here.

What processing activities do you undertake that include my personal information?

The scheme trustees use your Personal Information to administer your pension.

This includes facilitating the following activities:

  • communicating with you; 
  • dealing with disputes; 
  • requests or queries by you or third parties;
  • calculating and paying benefits to you from Scheme;
  • establishing your eligibility for benefits; 
  • calculating and managing contributions; 
  • allocating death benefits; 
  • transferring your benefits to another scheme;
  • investing pension scheme assets or making investment decisions; 
  • actuarial valuations to manage the scheme liabilities; 
  • taking steps to reduce risks affecting the security of your benefits; 
  • purchasing insurance products including annuities;
  • compliance with contracting-out requirements;
  • compliance with legal obligations and guidance issued by the Pensions Regulator; 
  • scheme audits; 
  • demonstrating that duties/requirements have been complied with; 
  • monitoring and payment of tax charges, reporting to/providing information required to HMRC;
  • preparing accounts; 
  • managing and defending legal claims; and/or
  • dealing with the sale, merger or reorganization of the scheme employers.
What categories of personal information are included in these processing activities?

We process pension information, Business information, Contact information, Data related to your engagement with the company, Employment claims, complaints and disclosures data (to extent that the individual is leaving employment), Financial data, Identity information, Staff related data, Remuneration and benefits data.

In addition we may hold any or all of the following personal information about you: 

  • documentary identifiers, such as information contained in or copies of passports, driving licences, birth certificates, gender recognition certificates (or their equivalent or replacement), marriage certificates, and other national documents, such as proofs of identity, residency, and employment;
  • family, lifestyle and social circumstances such as details of family, beneficiaries and dependents, including pension sharing order details; and 
  • financial details such as income, salary, assets and investments (including investment choices, if applicable), benefits, grants and insurance detail. 


For ill health retirement and managing liabilities, we also process health and medical information and for divorces we process court order information. This is special categories of personal information.

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.

What is the reason for these processing activities?

We use your personal information to ensure that your entitlement to pension is managed appropriately.

What are the legal grounds you rely on to carry these out?

This processing is necessary for the compliance with legal obligations to which the Company is subject.

This processing is also necessary for the purpose of the legitimate interests pursued by the trustees.

(See “What are the legal grounds for processing personal information?” in the Overview section.)

What are the 'legitimate interests' referred to above?

The appropriate management and administration of the scheme, including administration of member benefits (including calculation and payment of your pension), maintaining member records and communicating with members as well as ensuring appropriate governance of the scheme.

As this processing may include special categories of personal information, in addition to the above, what are the additional legal grounds you rely on to justify this processing?

This processing is needed for carrying out our legal obligations. These include pension and employment law requirements.

This processing is necessary for reasons of substantial public interest.

The processing may also be necessary for establishing, exercising or defending legal claims.

(See “What are the legal grounds for processing special category personal information?” in the Overview section.)

To the extent that you did not get this personal information from me, how did you collect this information?

If you are a member of the scheme we may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section), including:

  • your current or former employer (some of this personal information will come from MBDA, Roxel, RBSL, ARA or Airbus, depending on the identity of your former employer); 
  • any financial or other adviser or representative acting on your behalf and, if you want to transfer benefits, the trustee or managers of other pension schemes of which you are or have been a member;
  • providers of services that allow us to verify the accuracy of your personal data (for example, to trace your current address or to verify your continuing existence); and 
  • public databases (for example, the register of births, deaths and marriages), government agencies (for example, His Majesty's Revenue or Customs (HMRC) or the National Insurance Contributions Offices (NICO)

In ill-health retirement cases, personal information may be provided by medical advisers, such as Occupational Health.  We may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section).

If you are (or might be) eligible to receive benefits following the death of a member we may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section), including:

  • public records (for example, the register of Births, Deaths and Marriages); 
  • any adviser or representative acting on your behalf;
  • other people who knew or are related to, or were dependent upon the member, and anyone representing them;
  • the executors of the member's will or the member's personal representatives and anyone representing them.
Who do you share this personal information with?

Your personal information is shared internally, as set out in this Notice (see “When do you share my personal information with others?” in the Overview section).  This would usually include the Company, the pension administrator, tracing agents, governmental authorities (such as tax authorities), an Independent Financial Adviser, a new pension scheme (as appropriate), accountants and actuaries.

In addition, some of your personal information will be shared with MBDA, Roxel or Airbus (as appropriate).

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