GDPR—FAQs for pensions
Produced in partnership with Aneliese Sweeney of Arc Pensions Law LLP
GDPR—FAQs for pensions

The following Pensions practice note Produced in partnership with Aneliese Sweeney of Arc Pensions Law LLP provides comprehensive and up to date legal information covering:

  • GDPR—FAQs for pensions
  • What is the impact of Brexit on the GDPR?
  • Identifying data controllers and processors
  • Who are data controllers and data processors in a pension scheme?
  • Are actuaries data controllers?
  • Sensitive data
  • What type of pension scheme data is sensitive data?
  • Appointing a data protection officer
  • Do trustees need to appoint a data protection officer?
  • Could trustees share a data protection officer with the sponsoring employer?
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: Brexit and IP completion day—the implications for pensions.

This Practice Note answers some commonly raised queries faced by pensions lawyers in relation to Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), which came into force on 25 May 2018, and related issues. The Data Protection Act 2018 sits alongside the GDPR and sets out the framework for data protection law in the UK. It updates and replaces the Data Protection Act 1998.

For further information on the GDPR and the Data Protection Act 2018, see Practice Notes:

  1. Introduction to the EU GDPR and UK GDPR

  2. The GDPR for pensions lawyers

  3. The Data Protection Act 2018

What is the impact of Brexit on the GDPR?

The Withdrawal Agreement maintains the effect of the GDPR in the UK and allows personal data to continue to be transferred between the EEA and UK (and vice versa) during the implementation period in the same way

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