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Privacy Notice

(the “Scheme”)

BAA Pension Trust Company Limited (the “Trustee”), as the trustee of the Scheme, holds and processes personal data about Scheme members and beneficiaries in order to run the Scheme. In doing so, we comply with relevant data protection legislation. 

What we do with your data

As a data controller, the Trustee collects and processes your personal data for the purposes of complying with its legal duties to administer the Scheme and for other legitimate purposes relating to the operation of the Scheme, which include: 

  • calculating, administering and paying your benefits under the Scheme or following your death; 
  • processing ill-health retirement claims; 
  • dealing with any queries/complaints/appeals etc. regarding decisions we have made, for example in relation to your or your dependants’ entitlement to benefits under the Scheme; 
  • funding and de-risking the Scheme, and investing Scheme assets to provide benefits under the Scheme; 
  • carrying out actuarial valuations and investment of the Scheme’s assets; and/or 
  • compliance with legal, regulatory and good governance obligations and as otherwise lawfully permitted from time to time. 

The legal basis for doing so is in order for the Trustee to comply with its legal obligations. 

Whilst much of the data we hold has been provided by you, we also hold and process data provided by third parties such as LHR Airports Limited, the Scheme’s principal employer, and Heathrow Express Operating Company Limited as a participating employer in the Scheme (together the “Companies”), World Duty Free Limited and BAA Building Control Services Limited as former participating employers in the Scheme, other pension schemes from which members have transferred, HMRC, the DWP and regulatory bodies and by tracing organisations. We also receive information from you about your proposed beneficiaries, who would be eligible to receive benefits on your death. We assume that you have the consent of those individuals to provide us with this information and that you will share this privacy notice with them. We will not provide a copy of this notice to those individuals as to do so is likely to seriously impair our ability to properly pay the benefits due under the Scheme. The data we hold is to assist the Trustees in calculating and paying the benefits the members are entitled to. 

What data is processed?

The data we hold about you (and your beneficiaries) is to assist the Trustee in calculating, administering and paying benefits and includes (but is not limited to): 

  • full name, age, gender, date of birth, national insurance number, passport or ID number, and or other governmental identification numbers; 
  • business and/or personal contact details, including address, telephone numbers and email addresses;
  • financial information, including salary, tax information, pension or prospective pension entitlement, bank account details;
  • employment details, including years of service, dates of employment, full or part time employment status, job band, salary, compensation, employee claims, bonuses and benefits;
  • pension scheme status, including start date and leave date of joining the Scheme;
  • your preferences in relation to your pension benefits; and
  • marital status and relationship data, including the full name, date of birth, contact details and relationship to your family members, dependants and/or beneficiaries.

We also hold and process some special categories or “sensitive” data about individuals for the purposes of administering the Scheme (for example in relation to ill-health or death benefits). We will in most circumstances process this data as necessary for the establishment, exercise or defence of legal claims to benefits or in the performance of our legal obligations in connection with employment, social security and social protection (as allowed by legislation). If there are any occasions where we seek your explicit consent to process sensitive data then you can withdraw it at any time.

Who else processes your data?

We share your personal data with certain third parties involved in running the Scheme, for example, the Scheme’s administrator (currently Paymaster (1836) Limited (“Equiniti”)), the Scheme actuary and actuarial team (currently Chris Sheppard and Mercer Limited), the Trustee’s legal advisers (currently CMS Cameron McKenna Nabarro Olswang LLP), the Company’s legal advisers, the Scheme’s independent professional trustee (The Law Debenture (BAA) Pension Trust Corporation), the Scheme’s auditor (currently Crowe Clark Whitehill LLP), life assurance providers, AVC providers (including Aviva, JLT and Equitable Life), insurance providers, insurance and reinsurance companies (including Legal & General Assurance Society Limited), investment managers, medical advisers (including Business Health Resources Limited), communications providers (including Concert Consulting UK Limited and eShare Limited), tracing organisations (including Faraday Tracing Bureau Limited), HMRC, and DWP.

A copy of Legal and General's privacy policy can be found at

In addition, we make your personal data available to the Companies and any other employers associated with the Companies, or to companies and firms which are considering or have acquired one or both of the Companies or the whole of part of the Companies’ business, or the trustee(s), administrators or professional advisers of any pension scheme to or from which your rights under the Scheme may be, are being or have been transferred, or to any company participating in such a pension scheme.

Your personal data will also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from the Pensions Regulator, Pensions Ombudsman or any other regulator or any other legal process served on or involving the Trustee.

In some circumstances we are joint controllers with the Scheme Actuary, the Trustee’s legal advisers (who will process personal data to comply with their professional duties as advisors to the Trustee), insurers, auditors and the Companies. The Companies hold and process your data to comply with their legal obligations as the sponsoring and participating employers of the Scheme. The Companies have a legitimate interest in the Scheme being run in a cost effective way and may have an interest in offering certain options to members. The Trustee will share information with the Companies and their auditors and advisers for this purpose.

The Trustee, the Companies, Equiniti and other advisers will from time to time transfer Scheme personal data to other countries, including outside the European Economic Area. Where transfers are made outside the European Economic Area, the parties involved will ensure that adequate safeguards are in place and details of these safeguards can be made available on request.

Storage of your personal data

Pension benefits are paid over a long period and your right to benefits under the Scheme is based on information which may go back many years. Our policy is therefore to retain information relating to you until your membership of the Scheme ends.

Once your membership ends, we may decide to delete some of the data held in relation to you after 7 years. However, information will be held for longer where we consider it appropriate in order to ensure the Scheme pays the correct benefits and to deal with any queries relating to your benefits which may arise after that time.

Equiniti will hold on to your data for a maximum of up to 7 years after the termination of its contract with us. This is to protect themselves against any subsequent legal claims.

Your rights

You have the right to access your personal data and require that we rectify any errors in the data that we hold, or request that we erase your personal data. In some circumstances, you can also require that we restrict the way we process your personal data, object to its processing or request a copy of your personal data for the purposes of transmitting elsewhere. You can exercise these rights by contacting the Trustee at:

BAA Pensions
Sutherland House
Russell Way
West Sussex
RH10 1UH


Phone: 0333 207 6549

Please notify us as soon as possible if there has been a change in your details (for example if your personal circumstances such as your nominated beneficiary or home address change).

Where we have requested and obtained your consent to process particular information, you may withdraw that consent at any time. However, if we do not hold all the data we need to administer your benefits, we may not be able to pay out the benefits you are entitled to.

Contact details

If you want to know more about the information held by the Trustee, the purposes for which it is held or about the Scheme’s data protection arrangements, please contact the Trustee as follows:

BAA Pension Trust Company Limited
c/o Equiniti Paymaster
BAA Pensions
Sutherland House
Russell Way
West Sussex
RH10 1UH


Phone: 0333 207 6549

What if you have a complaint?

To make a complaint about how we have handled your personal data, please contact us as set out above. If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office. This is in addition to and separate from the Scheme’s internal dispute resolution policy. Its contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane

Phone: 0303 123 1113 or 01625 545 745

The Trustee reserves the right to amend this privacy notice from time to time.