This privacy notice has been prepared for the members and beneficiaries of Lothian Pension Fund (the "Fund"), a Local Government Pension Scheme. It has been prepared by the City of Edinburgh Council in it's capacity as the Administering Authority of the Fund.
We hold certain information about you and from which you can be identified (“personal data”) which we use to administer the Fund and to pay benefits from it. Inline with data protection legislation, as a data controller we are required to give you specified information about the personal data we hold about you, how we use it, your rights in relation to it and the safeguards that are in place to protect it. This notice is designed to give you that information and is available online at https://www.lpf.org.uk/privacy/.
Under the applicable law and regulations governing the Fund's activities, we have a duty to provide and administer pensions for our members and to invest and safeguard the assets of the Fund. So, usually, the reason we process your personal data is that we need to do so to satisfy our legal obligations as the administering authority of the Fund, including, for example, our obligations under the Local Government Pension Scheme (Scotland) Regulations 2018 or the pension dashboard regulations.
However, where the legal basis above does not apply, then the legal basis for our use of your personal data will be one or more of the following:
We need to process your personal data to carry out a task in the public interest or in the exercise of official authority in our capacity as a public body; or
We need to process your personal data to meet our contractual obligations to you in relation to the Fund (for example, under an agreement that you will pay additional voluntary contributions to the Fund), or to take steps, at your request, before entering into a contract.
The types of personal data we hold and process about you can include:
Contact details, including name, address, email address and telephone numbers
Identifying details, including date of birth, national insurance number, employee and membership numbers and, if you have used a pensions dashboard to access information about your pension, a "pension identifier" (PEI), which is used to confirm a match and identify your specific benefits under the Fund for the purposes of displaying information via a dashboard
Information that's used to calculate and access eligibility for benefits, for example, length of service or membership and salary information
Financial information relevant to the calculation or payment of benefits, for example, bank and tax details
Information about your family, dependants or personal circumstances, for example marital status and information relevant to the distribution and allocation of benefits payable on death
Information about your health, for example to assess eligibility for benefits payable on ill health (but note we do not normally require information on the underlying medical assessment to determine whether you are eligible) or where your health is relevant to a claim for benefits following the death of a member of the Fund
Information about a criminal conviction if this has resulted in you owing money to your employer or the Fund and the employer or Fund may be reimbursed from your benefits
Information about any previous membership of other public service pension schemes and other LGPS administering authorities, including your date of leaving and whether the previous scheme /authority has assessed your eligibility for underpin protection (see “How we will use your information” below).
We obtain some of this personal data directly from you by asking you to fill in forms on our website (and to register to use My Pension Online) or to subscribe to receive e-newsletters or other services. We may also ask you to take part in customer feedback to improve our services.
We will record:
Details of any services you request or amendments you make during visits to our website
Details of your visits to our online services, including your IP address
Correspondence you send to us, where appropriate.
When we’re in contact with you by phone, we’ll collect and store your phone number and a recording of the call.
In addition to the information you provide us, we may also receive personal data about you from other sources. We may obtain data (for example, salary information) from your current or past employer(s) or companies that succeeded them in business, from a member of LPF (where you are or could be a beneficiary of the Fund as a consequence of that person's membership of the Fund) and from a variety of other sources, including public databases (such as the Register of Births, Deaths and Marriages), a pensions dashboard (when you use it to access your pension information), our advisers and government or regulatory bodies.
Occupational health providers, AVC providers, solicitors, your previous pension scheme, and HMRC may also provide us with your personal data.
Where we obtain information concerning certain "special categories" of particularly sensitive data, such as health information or biometric data, extra protections apply under the data protection legislation. We will only process your personal data falling within one of the special categories with your consent, unless we can lawfully process this data for another reason permitted by that legislation. You have the right to withdraw your consent to the processing at any time by notifying us in writing. However, if you do not give consent, or subsequently withdraw it, we may not be able to process the relevant information to make decisions based on it, including decisions regarding the payment of your benefits.
Where you have provided us with personal data about other individuals, such as family members, dependants or potential beneficiaries under the Fund, please ensure that those individuals are aware of the information contained within this notice.
We use information held about you to administer your pension benefits and manage the Fund, including:
To contact you
To assess eligibility for, calculate and provide you (and, if you are a member of the Fund, your beneficiaries upon your death) with benefits
To identify your potential or actual benefit options and, where relevant, implement those options
To allow alternative ways of delivering your benefits, for example, through transfers to or mergers with other pension arrangements
To facilitate your access to your pension information via a pensions dashboard
For statistical and financial modelling and reference purposes (for example, when we assess how much money is needed to provide members' and beneficiaries' benefits and how that money should be in-vested)
To assess and, if appropriate, action a request you make to transfer your benefits out of the Fund
To comply with our legal and regulatory obligations as the administering authority of the Fund
To address queries from members and other beneficiaries and to respond to any actual or potential disputes concerning the Fund
In connection with the sale, merger or corporate reorganisation of or transfer of a business by the employers that participate in the Fund and their group companies
To allow alternative ways of delivering your benefits, for example, transfers to or mergers with other pension arrangements
To prevent fraud in relation to your pension benefits
To identify whether you qualify for underpin protection. For more information please see The McCloud Remedy :: LGPS Scotland
From time to time we’ll share your personal data with advisers and service providers so they can help us carry out our duties, rights and discretions in relation to the Fund. Some of those organisations will simply process your personal data on our behalf and in accordance with our instructions: they are referred to as processors. Other organisations will be responsible to you directly for their use of personal data that we share with them; they’re referred to as controllers. The controllers may be obliged under the data protection legislation to provide you with additional information regarding the personal data they hold about you and how and why they process that data. Further information may be provided to you in a separate notice or may be obtained from the advisers and service providers direct, for example via their websites. In each case, we’ll only share data to the extent that we consider the information is reasonably required for these purposes.
Whenever one of our advisers or service providers acts as a joint controller with us in respect of your personal data, because we jointly determine the purposes and means of processing it, we’ll agree with them how we are each going to meet our respective and collective obligations under the data protection law. If you would like more information about how such arrangements work, please get in touch using the contact details below.
The organisations that we may share your personal data with may include the following advisers and service providers:
Processors | Controllers |
The pensions administration software provider delivers technical and management support for its electronic pensions administration systems. It's also our integrated service provider, facilitating connections to a pensions dashboard and the provider of bank verification services for identity verification and fraud prevention purposes. |
The Scheme Actuary provides services for the purpose of calculating the Fund’s assets and liabilities and setting employer contribution rates. For more information on how we work with our current actuary please visit Hymans Robertson. |
Longevity (life expectancy) analytics and related information provider helps to manage the Fund's liabilities. |
The occupational health services in connection with matters such as ill-health retiral applications for deferred members. |
Tracing services providers for mortality screening/existence checks and locating members and beneficiaries. | Legal advisers in connection with providing advice on issues related to specific members. |
Overseas payment services providers support the transmission of overseas payments to Fund members and beneficiaries with non-UK accounts. | AVCs providers who and create and manage individual member AVC accounts. |
The managed IT service provider. |
The administrator of the LGPS National Insurance Database for the purpose of identifying if Fund members have benefits in other LGPS schemes.
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Document production and distribution service providers. | Administering authorities of other LGPS funds (or their agents, such as third-party administrators), depending on circumstances, where a member has also had service with another LGPS fund, and the information is needed to determine the benefits to which the member or their dependants are entitled.
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| Department for Work and Pensions (DWP) provides the Tell Us Once service for the purpose of notifying us of the death of scheme members. |
The UK Courts – for the purpose of processing pension sharing orders on divorce. | |
Money and Pensions Service |
From time to time we may provide some of your data to your employer and their relevant subsidiaries (and potential purchasers of their businesses) and advisers for the purposes of enabling those entities to understand the liabilities and obligations of the employer regarding the Fund. Your employer would generally be a controller of the personal data shared with it in those circumstances. For example, where your employment is engaged in providing services subject to an outsourcing arrangement, the Administering Authority may provide information about your pension benefits to your employer and to potential bidders for that contract when it ends or is renewed.
The pensions dashboard framework requires us to share personal data within the dashboards ecosystem. When a member searches for information about their pensions online via a pensions dashboard, we receive certain personal data for the purposes of identifying a match with the member's pension in the Fund. We then need to provide certain pensions information to the dashboards ecosystem so that it can be displayed via the relevant dashboard.
Where requested or if we consider that it is reasonably required, we may also provide your data to government bodies and dispute resolution and law enforcement organisations, including those listed above, the Pensions Regulator, the Pensions Ombudsman and HM Revenue & Customs (HMRC). They may then use the data to carry out their functions.
The organisations referred to in the paragraphs above may use the personal data to perform their functions in relation to the Fund as well as for statistical and financial modelling (such as calculating expected average benefit costs and mortality rates) and planning, business administration and regulatory purposes. They may also pass the data to other third parties, to the extent they consider the information is reasonably required for a legitimate purpose.
In some cases, recipients of your personal data may be outside the UK. As such, your personal data may be transferred outside the UK to a jurisdiction that may not offer an adequate level of protection as is required by the UK Government.
If this occurs, additional safeguards must be implemented with a view to protecting your personal data in accordance with applicable laws. Please use the contact details below if you want more information about the safeguards that are currently in place
Your data won’t be kept for any longer than it is needed by us to carry out our processing activities, and for so long afterwards as we consider may be required to deal with any questions or complaints about the administration of the Fund, unless we elect to retain your data for a longer period to comply with our legal and regulatory obligations.
We have a Records Retention Schedule which governs how long records containing your personal data will be kept. In practice, this means that your personal data will be retained for such period as you (or any beneficiary who receives benefits after your death) are entitled to benefits from LPF and for a suitable period after those benefits stop being paid. For the same reason, your personal data may also need to be retained where you have received a transfer, or refund, from LPF in respect of your benefit entitlement.
Where you seek to access your pensions information via a pensions dashboard, we will retain certain data relating to that access (some of which includes personal data) as required by pensions dashboard regulations and relevant regulatory guidance.
You have the right to request access to any data which we may hold about you. If any information kept about you is inaccurate or incomplete, you have the right to request that the information be corrected. In very limited circumstances, you may also have a right to ask us to restrict the processing of your personal data, or to transfer or (in extremely limited circumstances, such as where your personal data is no longer needed for the purpose for which it is being processed) erase your personal data. You should note that we are not obliged to erase your personal data if we need to process it for the purposes of administering the Fund.
In certain circumstances, you have the right to object to the processing of your personal data; for example, you have the right to object to processing of your personal data which is based on the public interest or legitimate interests identified in the section above headed ‘Basis for processing my personal data?’.
You can obtain further information about your rights from the Information Commissioner's Office at www.ico.org.uk or via its telephone helpline (0303 123 1113).
If you wish to exercise any of these rights or if you have any queries, complaints or concerns regarding the processing of your personal data, please contact the Fund or our Data Protection Officer using the details provided below. You can submit a data protection complaint to us by filling in our complaints form, which is available at Complaints and appeals.
You also have the right to lodge a complaint in relation to this privacy notice or our processing activities with the Information Commissioner's Office, which you can do through the website above or their tele-phone helpline.
As explained above, one of the reasons we collect and hold your personal data is to administer your benefits. If you don’t provide the information we request, ask that the personal data we already hold is deleted or that the processing of the personal data be restricted, this may affect our ability to administer your benefits, including the payment of benefits from the Fund. In some cases, it could mean we are unable to put your pension into payment or have to stop your pension, if already in payment.
If you have a question, please use one of the following ways to get in touch:
Email: pensions@lpf.org.uk
Telephone: 0333 996 1900
Mail: Lothian Pension Fund, PO Box 24158, Edinburgh, EH3 1GY
The Fund’s Data Protection Officer is Kevin Willbraham, Information Governance and Strategic Complaints Manager Information Governance Unit, City of Edinburgh Council Waverley Court – 2.1, 4 East Market Street Edinburgh EH8 8BG, E-mail: information.compliance@edinburgh.gov.uk , Tel: 0131 469 6200.
We may update this notice periodically. Where we do this, we will inform members of the changes and the date on which the changes take effect.
This Privacy Notice was last updated in June 2026.