Search site

Privacy Notice

The Data Protection Act 2018 (DPA) requires organisations to be more transparent and accountable to individuals about how it manages and controls their data. This Privacy Notice, sets out how the West Midlands Pension Fund manages its members' data, including who it shares data with and for what purpose it might be used.

The City of Wolverhampton Council (The Data Controller) administers the Local Government Pension Scheme (LGPS) on behalf of all public body employers throughout the West Midlands, including the 7 District Councils and trades as the West Midlands Pension Fund administering the Local Government Pension Benefits of over 300,000 members.

The Fund holds personal information about individuals so that it can provide the pension services to members and employers. The Fund has a legal basis for the holding and processing of data which is section 8 (c) of the DPA. To elaborate, section 8 (c) states:

[...] processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of the controller's official authority includes processing of personal data that is necessary for- (sub section c) the exercise of a function conferred on a person by an enactment or rule of law,

The Fund is a statutory scheme thus in its operation it holds a statutory duty to provide pensions for all its members. In other words, the Fund can hold and process data thanks to having a statutory authority to carry out its function.  

The Fund has a legal obligation and a statutory duty (under the DPA) to provide individuals with certain information under a number of regulations, including;

  • The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013

  • The Pensions Act 2011 (Transitional, Consequential and Supplementary Provisions) Regulations 2014

  • The Occupational and Personal Pension Schemes (Disclosure of Information) Amendment Regulations 2015

  • The LGPS Regulations 2013

  • The Public Service Pensions Act 2013

  • The Pensions Act 2004

    Under these Regulations, the Fund has a legal requirement to provide individuals with the following

  • Basic information to members on the LGPS on joining or upon request by other parties

  • Information to early leavers and those retiring from the LGPS

  • Information on request relating to transfer to and from the LGPS

  • Issue Annual Benefit Statements to Active, Deferred, Deferred Pensioner and Pension Credit members of the LGPS no later than 31 August each year

  • Information regarding changes to the Regulations that govern the LGPS that may affect the calculation of a member's benefits.

    The Fund may if it chooses, pass certain details to a third party, if that third party is carrying out an administrative function of the Fund, for example, the Fund's appointed Actuary organisation.

    The Fund may also collect personal information from members as part of its Customer Feedback Strategy, where contact details may be requested to further the provision of a service or to offer further opportunities for engagement. These are collected on a purely voluntary basis and will be managed in line with the Fund's Information Governance Framework.

    By law, the Fund are also required in certain circumstances to share members' information with government organisations such as Her Majesty's Revenue and Customs and the Department for Work and Pensions so that they ensure that public funds are safeguarded. Information may also be shared in the prevention and detection of fraud.

    Who we may share your information with

    The West Midlands Pension Fund may share or disclose personal information with any of the following bodies or organisations as may be necessary to administer the scheme in line with statutory obligations and/or to comply with contractual obligations relating to it. In certain circumstances, these bodies may also be data controllers in their own right.

Who we share your information with

Type of Service/Advisor

Name of Body/organisation

Reasons for sharing the personal data

Scheme Actuary

Barnett Waddingham

To calculate the value of the Fund's assets and liabilities based on its membership profile and to set employer contribution rates based on that information.

Scheme AVC Provider*


To facilitate the creation and maintenance of individual member's AVC accounts

Scheme Auditor

Grant Thornton

To facilitate the statutory duty of auditing the Fund's Annual Report and Statement of Accounts and internal controls

LGPS National Insurance Database

South Yorkshire Pension Authority

To enable the Fund to identify if their members have benefits in other LGPS schemes to ensure that appropriate benefits are paid.

Regulators, the government, law enforcement bodies including local and foreign courts, tribunals and arbitrators.

National Fraud Initiative

Government Actuary Department

The Pensions Regulator

The Scheme Advisory Board

To comply with the Fund's statutory duty in the management and administration of benefits, this includes participation in the Cabinet Office's National Fraud Initiative for the purposes of the prevention and detection of fraud against the Fund and organisations within the public sector and the Government Actuary's department for the calculation of the triennial assessment of the cost of the Local Government Pension Scheme on a national basis as per the Public Service Pensions Act 2013.

The Fund's software provider for its pension administration system


To provide software management support in the delivery of the Fund's electronic pension case management and benefit calculation system.

Independent Investment Advisors


To support the Fund in determining its investment strategy based on its liabilities as determined by its membership profile.

Stakeholder Engagement tools

Survey Monkey

Event Brite

To assist the Fund in communicating with and gaining feedback from key stakeholders including Members and Scheme Employers. 

These services are purely voluntary to undertake, by the submitting of information via these tools individuals are consenting to the use of their data by the Fund for the purposes of engaging on services provided.    

Third-Party Contractors

Available upon Request

The Fund contracts third-party organisations on an ad-hoc basis to carry out services as and when required on our behalf. Information regarding these organisations is available upon request. 

*The Fund is required by law to have an additional voluntary contributions provider (AVC). The West Midlands Pension Fund partners with Prudential to provide AVC options to its members. Through that arrangement, Prudential may have access to members' contact details in order to provide information and options in relation to AVC's.

Who may have access to your personal information?

The Fund procures the services of a number of suppliers who support the various electronic systems and software at the Fund. Those suppliers may have access to the personal data held by the Fund for the purposes of supporting the IT infrastructure only, they will not have access to the information for any other purpose.

Retention Periods

Under the DPA individuals have the right to have the information held about them deleted or removed from databases maintained by data controllers.

The Fund, in providing statutory duties under the regulations has determined that it cannot permanently delete a member's record. Member details and documentation are required to be retained to enable the Fund to comply with statutory and legal obligations. However, if a request is made to delete member details or documentation, it will be considered on a case-by-case basis.

For more in information about our data retention periods please refer to our Data Quality Policy document which can be found here.

Lodging complaints about the handling of data

Data subjects have the right to lodge a complaint with higher supervisory authorities if they suspect a data controller has unlawfully restricted access to their data or if the data controller has refused their request to the erasure of specified data without sufficient grounds. s.51 of the DPA fully outlines the circumstances where such complaints can be made. Please refer to the Funds' Data Protection Policy (link below) for our statement with regards to our Data Subjects' individual rights under current data protection legislation.  

The supervisory authority that regulates the Information Governance of the Fund is the Information Commissioners Office (ICO).  For more information making a complaint about how data controllers such as the fund handle/process your data please contact the ICO on their website which is linked here:   

For more information relating to a member's rights under the DPA and GDPR, please click on "Your Rights" tab on the left hand side. For a more in depth explanation of data protection laws with regards to individual rights please view our Data Protection Policy document found here.

To contact us for any further queries, please email our Data Protection Officer at



Powered by GOSS iCM