Scottish Public Pensions Agency's access to birth certificate information: FOI release

Information requested

1. Does SPPA access birth certificate serial numbers via ScotlandsPeople or other interfaces?

2. What statutory purpose justifies this access?

3. What is the lawful basis under UK GDPR for processing this data?

4. Are any DPIAs, internal reviews, or risk assessments available?

5. Is the data retained, indexed, or linked to pension eligibility or identity verification systems?

6. Is this access governed by a formal agreement with NRS or the Scottish Government?

Response

1. No. The SPPA does not access birth certificate serial numbers via ScotlandsPeople or through any other channels.

2. The SPPA does not access birth certificate serial numbers. The ScotlandsPeople database is not used by the SPPA for this purpose.

3. As the SPPA does not access birth certificate serial numbers, there is no applicable lawful basis under UK GDPR for such access.

4. As the SPPA does not access birth certificate serial numbers, no Data Protection Impact Assessments (DPIAs), internal reviews, or risk assessments have been conducted in relation to this type of data.

5. Birth certificate serial number data is not accessed, retained, indexed, or used by the SPPA for pension eligibility or identity verification systems.

6. There is no formal agreement between the SPPA and National Records of Scotland (NRS), or any third-party data processor, for access to birth certificate serial numbers. The SPPA has permissions to access birth, death, and marriage records via the ScotlandsPeople database. However, in practice, the SPPA accesses death certificate data, and solely for the purposes of administering to the Pension Schemes they manage. Birth certificate data, including serial numbers, is not accessed or used.

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