THE PEARSON PENSION PLAN: DATA PRIVACY NOTICE
Pearson Pension Trustee Limited (“we”, “our” “us”), the trustee of The Pearson Pension Plan (the “Plan”), is committed to protecting your personal information and acting in accordance with your rights under data protection law.
This privacy notice contains information on:
- what personal information about you is collected by us;
- what we do with your personal information;
- the lawful basis on which your personal information is processed; and
- what rights you have.
1. Collection of your personal information
We collect and process the following personal information about you:
- Personal details: your personal details which can include your name, gender, date of birth, home address (including postcode), telephone number, e-mail address, National Insurance number, bank account details and country of residence;
- Benefits information: information relating to your benefits, such as your member identifying number (which is assigned to you by us), the date you joined or left the Plan, your earnings and pensionable earnings, the category and value of the benefits that you have built up or receive and relevant matters impacting your benefits such as voluntary contributions, pension sharing orders (including information in divorce or dissolution certificates), tax protections or other adjustments;
- Records of communications with you (including any complaints);
- Special categories of personal data: in some cases, special categories of personal information such as your biometric data (e.g. your picture or your fingerprint), your marital status or information concerning your health (e.g. in the case of ill-health early retirement and ill-health reviews, and where incapacity or similar reasons determine the benefits paid to you); and
- Beneficiary information: where applicable, we also collect personal information about your nominated beneficiaries, dependants or next of kin (for example, when you submit an Expression of Wish form). Before providing us with any such information, we ask that you provide a copy of the information in this notice to those individuals. We will assume that you have the authority to share any personal information you provide to us about them.
In some cases, we will collect personal information about you indirectly from the Pearson Group entity which is (or was) your employer, from HM Revenue & Customs where this relates to the contracted-out benefits payable from the Plan, and from our service providers (e.g. our administrators, which currently are Pearson Pension Trustee Services Limited, Aviva Life and Pensions UK Limited, and Capita).
In this notice, we will refer to the personal information which we collect about you and your nominated beneficiaries, dependants or next of kin as your “Personal Information”.
2. Our legal basis for processing
Our use of your Personal Information as described above is permitted by applicable data protection law because:
- it is necessary for our legitimate interests in pursuing the purposes set out in the table in section 3 below, and (when we make disclosures to the Pearson Group (for the audit and corporate transaction purposes referred to below), necessary for Pearson Group’s legitimate interests in prudential management and meeting its regulatory requirements, such interests not being overridden by your privacy interests (“Legitimate interests”);
- it is necessary for one of the legitimate interests formally recognised by the UK General Data Protection Regulation (in which case no balancing of interests is required) (“Recognised legitimate interests”);
- it is necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies referred to below (“Legal obligations”);
- it is necessary for the performance of a task carried out in the public interest and, when we use special categories of personal data, necessary for preventing fraud or other unlawful acts, for establishing, exercising or defending legal claims or, where the processing relates to personal data, manifestly in the public domain; and
- it is processed with your consent, which we obtain from you from time to time, such as when you ask us to make disclosures or allocate benefits, or where the Plan rules require you to provide information which we cannot otherwise process without your consent.
Where the Personal Information we collect from you is needed to either:
- meet our legal or regulatory obligations; or
- record, calculate or pay benefits to you, or your nominated beneficiaries,
then, if we cannot collect or continue to use this Personal Information, we may be unable to administer your contributions and benefits, or record, calculate or pay your benefits and/or the benefits due to your beneficiaries.
3. How we use your Personal Information
We use your Personal Information for the purposes and lawful bases as set out in the table below:
| Purpose | Information | Legal basis |
| Communicating with you in relation to your benefits and contributions, handling requests for transfers and allocation of death benefits, dealing with complaints, and making disclosures at your request such as in relation to transfers to other plans |
| Legal obligation Legitimate interests Our legitimate interests are to discharge our obligations to you arising from the terms of the Plan and handle your requests and communications in relation to your benefits. |
| Special categories of personal data | We will either process your special categories of personal data for the significant public interest in providing an occupational pension scheme or with your consent. If you provide your consent, you can withdraw it at any time. | |
| General administration of the Plan, including: to record and pay benefits; for making a determination in connection with eligibility for or the amount of benefits payable under the Plan; for actuarial valuations; for selecting member nominated trustee directors; for providing you with news about the Plan; for reviews which we or our administrators conduct from time to time for statistical and reference purposes; and for other checks or administrative activities that may become necessary from time to time (like member tracing) should we happen to lose contact with you and to prevent fraud |
| Legal obligation Legitimate interests Our legitimate interests are to discharge our obligations to you arising from the terms of the Plan and administer the Plan on a day-to-day basis (e.g. recording and paying benefits; actuarial valuations; selecting member nominated trustees; reviews for statistical and reference purposes). Recognised legitimate interests We rely on this for processing that is necessary for the detection, investigation or prevention of crime. |
| Special categories of personal data | We will either process your special categories of personal data for the significant public interest in providing an occupational pension scheme or with your consent. If you provide your consent, you can withdraw it at any time. | |
| Meeting our ongoing regulatory, legal and compliance obligations, and investigating or preventing crime |
| Legal obligation Recognised legitimate interests We rely on this for making disclosures of personal data in response to requests from bodies carrying out public tasks, and the detection, investigation or prevention of crime. |
| Special categories of personal data | We will process your special categories of personal data for the significant public interest in the functions of relevant official or regulatory bodies, or investigating or preventing crime. | |
| Improving our processes and our use of technology |
| Legitimate interests Our legitimate interests are to discharge our obligations to you arising from the terms of the Plan, and make the administration of the Plan more efficient. |
| Undertaking activities from time to time to help manage the liabilities of the Plan |
| Legitimate interests Our legitimate interests are to manage the liabilities of the Plan. |
| Special categories of personal data | We will either process your special categories of personal data for the significant public interest in providing an occupational pension scheme or with your consent. If you provide your consent, you can withdraw it at any time. | |
| Complying with our legal obligations under the Pensions Dashboards Regulations 2022 | Personal details Benefits information | Legal obligation |
4. Disclosures of your Personal Information
We typically share your Personal Information with the recipients set out in the table below:
| Recipient | Information | Purpose |
| Suppliers | ||
| Service providers who administer the Plan on our behalf (currently Pearson Pension Trustee Services Limited, Aviva Life and Pensions UK Limited and Capita Pension Solutions Limited) |
| Day-to-day administration of the Plan |
| Financial advisers (currently Wealth at Work Limited) | Personal details Benefits information | Providing you with financial advice |
| Payroll providers (currently Capital Pension Solutions Limited) |
| Recording and paying benefits |
| Medical advisers (currently People Asset Management Limited trading as PAM Group) |
| Advising in relation to ill-health retirement cases |
| Providers of printing and communication services (currently Design Consulting Limited trading as Landscape, Capita Business Services Limited and Paragon Customer Communications (London) Limited) | Personal details |
|
| Providers of tracing and identity checking services (currently LexisNexis Risk Solutions UK Limited and Capita Pension Solutions Limited) |
| Tracing members and beneficiaries |
| IT and hosting providers (currently Pearson Pension Trustee Services Limited, Diligent Boardbooks Limited and Capita Pension Solutions Limited) |
| – IT services – Hosting services |
| Marketing providers |
| Providing marketing services in connection with the Plan |
| Additional Voluntary Contributions (“AVCs”) providers (currently Aviva Life and Pensions UK Limited, The Prudential Assurance Company Limited, Phoenix Life Limited, The Royal London Mutual Insurance Society Limited and Scottish Widows) |
| Investing your AVCs |
| Death in service insurers (currently Aviva Life and Pensions UK Limited) |
| Providing death in service insurance in connection with the Plan |
| Professional advisers | ||
| Plan actuary (currently XPS Pensions Group) |
| Actuarial advice |
| Legal advisers (currently Linklaters LLP) |
| Legal advice in relation to the Plan |
| Investment advisers (currently Lane Clark & Peacock LLP) |
| Investment advice in relation to the Plan |
| Risk settlement advisers (currently Lane Clark and Peacock LLP) |
| Risk settlement advice in relation to the Plan |
| Plan auditors (currently Crowe UK LLP) |
| Audit services for the annual report of accounts |
| Other recipients | ||
| Pearson Plc and its subsidiaries |
|
|
| Any new pension provider you select |
| Transferring your benefits to your new pension provider, if requested by you |
| Insurance and reinsurance companies (currently Aviva Life and Pensions UK Limited and Legal and General Assurance Society Limited) |
| Carrying out the de-risking activities referred to in paragraph 2(e) above |
| Miscellaneous third parties |
|
|
| Official and regulatory bodies | ||
| Public authorities, regulators and government bodies (such as the Pensions Regulator, HM Revenue & Customs and the Department for Work and Pensions) |
|
|
| Pensions dashboards service providers (such as the Money and Pensions Service and technology providers that facilitate the dashboards connection) (currently Aviva Life and Pensions UK Limited and Capita Pension Solutions Limited) |
| Complying with our legal obligations under the Pensions Dashboards Regulations 2022 |
Please note that when we share your Personal Information with our suppliers and service providers, we take steps to ensure they meet our data security standards, so that your Personal Information remains secure.
5. Transfers of your Personal Information abroad
The use and disclosure of your Personal Information for the purpose referred to in paragraph 2(b) and (e) above may involve transferring your data to countries outside of the UK or the European Economic Area (the “EEA”). Those countries, currently, may include India and the Philippines in accordance with the terms agreed with the service providers who administer the Plan on our behalf (currently Pearson Pension Trustee Services Limited, Aviva Life and Pensions UK Limited and Capita).
In those cases, except where the relevant country has been determined by the relevant public authority to ensure an adequate level of data protection, we will ensure that the transferred personal information is protected in compliance with applicable data protection rules. To ensure an appropriate level of protection, we typically use a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or (where applicable) relevant authority in the United Kingdom. Further details of these transfers and copies of these agreements are available from us on request.
6. Retention of your Personal Information
We will keep your Personal Information for the longer of: (i) the period required in order to meet our legal or regulatory responsibilities; and (ii) the period envisaged within our retention management systems.
We will decide the retention period having regard to the Plan’s operational and legal requirements, such as: facilitating the payment of benefits to you or your nominated beneficiaries; calculating and managing the liabilities of the Plan; and responding to legal claims or regulatory requests. In general, we will keep your Personal Information for twelve years after you (and your nominated beneficiaries or dependants) have stopped being entitled to any benefits from the Plan.
7. Your rights
You have rights under data protection law to access and correct your Personal Information and (in some circumstances) to restrict its use or have it deleted.
In some circumstances, you also have the right to object to the processing of your Personal Information and to require certain Personal Information to be transferred to you or a named third party.
Where we process your personal data to comply with legal obligations (such as the Pensions Dashboards Regulations 2022), certain rights (such as the right to object or the right to erasure) may not apply because we are required by law to carry out that processing.
You can exercise any of these rights by contacting us at the details set out below.
You also have the right to withdraw your consent to the use of your Personal Information, to the extent such use is based on your consent. You can notify us of your withdrawal of consent by contacting us at the details set out below.
Making a complaint
If you have concerns about how we use your Personal Information, you have the right to make a data protection complaint directly to us. We have a formal process to handle such complaints.
If you wish to make a complaint, please complete the Data Protection Complaint Form available on our website, or contact us using the details below.
We will acknowledge your complaint within 30 days and will take appropriate steps to investigate and respond without undue delay.
We encourage you to raise concerns with us in the first instance so that we can investigate and resolve the issue.
If you are not satisfied with our response or the outcome of your complaint, you have the right to refer your complaint to the ICO using their online service at: https://ico.org.uk/make-a-complaint/data-protection-complaints/. The ICO’s details are as follows:
Address: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Helpline number: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/ - This link opens in a new browser window
8. Further information required to carry out requests
In some cases, it will be necessary to obtain additional information from you, for example in order to carry out your request for a transfer or allocation of benefits. We will notify you when your information is required for this purpose.
9. Status of this privacy notice
This privacy notice was last updated on 23 July 2026.
This document is a notice to you and not a contract between us. It may be subject to amendments from time to time.
Any future changes or additions to our processing of personal information (as described in this privacy notice) which affect you, will be brought to your attention in a way which is appropriate, having regard to the way in which we normally communicate with you.
To contact us about the matters set out above, please contact the Secretary to the Trustee, Pearson Pension Trustee Limited, PO Box 645, Darlington, DL1 9HP or by using our website at: www.pearson-pensions.com/contact-us or you can email us at: pensions.helpline@pearsonpensions.com or you can also call us on 0800 7811378. Further details about the use of members’ personal information by the Plan actuary (XPS Pensions Group) is set out in their full Privacy Policy available online at: www.xpsgroup.com/legal-regulatory/privacy-policy/ - This link opens in a new browser window
