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United Kingdom

UK pensions law update: GDPR claims without third-party access; Targeted Support/guided retirement; Pension Schemes Bill concerns; HMRC Scheme Pays/pension relief changes; TPR secures DB scheme rescue

Published on: 28 August 2025

Published by a LexisNexis Pensions expert
Legal News
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Article summary

In this issue:

  • Data protection
  • Retirement options
  • Pension Schemes Bill
  • Taxation
  • The Pensions Regulator
  • Dates for your diary
  • Trackers

Data protection

GDPR breach doesn’t require proof of third-party access (Farley v Paymaster (1836) Ltd [2025] EWCA Civ 1117)

In Farley v Paymaster (1836) Ltd, the Court of Appeal reversed the High Court’s ruling ([2024] EWHC 383 (KB)) which had struck out data protection claims raised by pension scheme members after the scheme administrator, having failed to update its database, sent annual benefit statements containing personal data to out‑of‑date addresses. The officers pursued claims for data misuse and GDPR breaches, seeking compensation for non‑material harm—namely anxiety, alarm, distress and embarrassment—on the basis that their personal data had been posted to unknown third parties. At first instance, most claims were struck out because the claimants were found not to have a real prospect of success, due to insufficient evidence of damage and no act amounting to misuse, since many could not show that any third party had in fact opened the letters...

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