Personal Data Retention Policy

This notice explains how long Avon Pension Fund keeps personal data about members and beneficiaries, and why.

Bath and North East Somerset Council is the Administering Authority for the Fund and is responsible for keeping and protecting personal data in line with data protection law and pension legislation.

This notice should be read alongside our Privacy Notice, which explains how and why we use personal data and your rights.

Why we keep personal data for long periods

Pensions are long‑term arrangements. In many cases, benefits are paid many years after membership ends and may continue to beneficiaries after a member’s death.

We therefore need to keep personal data for extended periods so that we can:

• calculate and pay pension benefits correctly;
• deal with queries, disputes or complaints;
• meet legal, regulatory and audit requirements;
• deal with legal claims where they may arise many years later.

Data protection law allows this where keeping the data is necessary for these purposes.

Types of personal data we keep

We keep personal data such as:

• contact and identifying details;
• employment and pension records;
• financial information needed to pay benefits;
• information about family members or beneficiaries;
• health information where relevant to benefit decisions;
• limited criminal conviction data where required to recover monies owed.

More detail about the data we use is set out in our Privacy Notice.

How long we keep personal data

We only keep personal data for as long as it is needed for lawful purposes.

In practice, personal data relating to members and beneficiaries is kept for the longest of the following periods:

• while benefits are payable, and for 15 years after benefits stop; or
• 100 years from a member’s date of birth; or
• 100 years from the date of birth of a beneficiary who receives benefits after a member’s death.

These timeframes reflect the long‑term nature of pension schemes and are consistent with legal and regulatory expectations.

Deletion of data and system limitations

Some of our core pension administration systems do not currently allow records to be permanently deleted without affecting the integrity of pension benefit records.

Where personal data is no longer actively needed:

• its use is restricted;
• it is kept secure and used only where legally necessary.

We intend to permanently delete electronic personal data when system functionality allows and where this can be done in line with pension legislation and record‑keeping requirements.

Keeping data accurate

While we hold personal data, we take reasonable steps to:

• keep it accurate and up to date; and
• correct or delete information that is wrong where appropriate.

We regularly review the data we hold to make sure it is still needed.

Your rights

Members and beneficiaries have rights under data protection law, including the right to:

• access personal data we hold;
• ask for corrections;
• object to or restrict processing in certain circumstances;
• request erasure in very limited situations.

Because we are legally required to pay and administer pensions, some rights may be restricted where exercising them would prevent us from meeting those obligations. This is explained in more detail in our Privacy Notice.

Participating employers

This retention notice applies to Bath and North East Somerset Council in its role as the administering authority of the Avon Pension Fund.

Employers that participate in the Fund are responsible for managing and retaining their own employment records in line with data protection law. We provide separate guidance to employers about the information they may need to share with us for the administration of the Fund.

Review of this notice

We keep this retention notice under regular review and update it when necessary.

Version 6: April 2026