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Categories of personal data and whether sold or reported to credit agencies

FOI reference - FOI-6370
Date - 6 October 2021


  1. I would like to understand, in detail, the categories of personal data that your organisation holds about people, (eg name, address, right to work, digital activity, banking data, number of children a person has, DOB, conviction records, default data etc), that can be linked to an individual.

  2. Secondly, if (and how) this data is sold or reported to Credit Reference Agencies, and their particular relationship with your organisation (eg are you involved in any data sharing agreements? Or, do they purchase any particular data or datasets from you?).


I can confirm that we hold some of the information you have requested.

Information we are able to supply


Categories of personal data held by TPR Categories of individuals for whom TPR holds this category of personal data
Name Individuals who contact, work for, or are regulated by TPR
Email address Individuals who contact, work for, or are regulated by TPR
Job title Individuals who contact, work for, or are regulated by TPR
Address Individuals who contact, work for, or are regulated by TPR
Telephone number Individuals who contact, work for, or are regulated by TPR
PAYE reference Employers, Individuals who are not employers
Letter code Employers, Individuals who are not employers
Employer name Employers
Employer address Employers
Employer phone number Employers
Employer email address Employers
Pension provider Employers
PSR Number Employers
Number of eligible employees Employers
Number of employees enrolled Employers
Notice reference number Employers
Pension scheme details Employers
Workforce numbers Employers
Communications with staff Employers
Opt-out notices Employers
Proof of payment contributions Employers
Employment contracts or redundancy notices Employers
PAYE scheme information Employers
Insolvency details Employers
Proof that individual is not an employer Individuals who are not employers
Organisation name Employers
Company house number Employers
Title Individuals who contact, work for, or are regulated by TPR
Notice reference number Employers
Sort code Employers and TPR staff
Account number Employers and TPR staff
Employee email address Employees
Month and Year of Birth Employees
Mothers Maiden Name Pension trustees
Payroll history Employers and TPR staff
Illness / Health records TPR staff
Age TPR staff
Description of reason for hardship including disability and illness Employers
Employment contract status TPR staff
CV / cover letter (successful applicant) TPR staff
CV / cover letter (unsucessful applicants) Applicants for jobs at TPR
Next of kin TPR staff
Date of Birth TPR staff
National insurance number TPR staff
Qualifications TPR staff
Bank details TPR staff
Annual leave details TPR staff
Flexi-time details TPR staff
Sick leave details TPR staff
Performance details TPR staff
Contract of employment TPR staff
Resignation, severance, termination and/or retirement TPR staff
Pension details TPR staff
Reward and benefit details TPR staff
Disciplinary record TPR staff
Maternity / paternity leave requests and correspondence TPR staff
Photo of employee TPR staff
Trade union membership TPR staff
Race / ethnic origin TPR staff
Religious / philosophical belief TPR staff
Sexual orientation TPR staff
Disability TPR staff
Health TPR staff
Political activity TPR staff
Criminal history data / DBS checks TPR staff
Fit and proper' criteria Individuals working for pension schemes
Occupation Individuals working for pension schemes
Employees job performance record TPR staff

Information we are unable to supply

Section 44(1)(a) – restricted information under s82 PA04

  1. As we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us. Some of the type of information you have requested would be ‘restricted information’. Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04) as:

    ‘…information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.

    Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.

    Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a) of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment. In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose the requested information. This exemption is absolute and does not require a public interest assessment be undertaken.

  2. TPR does not sell or report the data mentioned in your first question to Credit Reference Agencies.