FOI reference - FOI-6370
Date - 6 October 2021
Date - 6 October 2021
Request
- 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.
- 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?).
Response
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
- 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.
- TPR does not sell or report the data mentioned in your first question to Credit Reference Agencies.