Privacy Notice

As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.

This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.

“We”, “Us” “Our” refers to the Partner named on this website.

Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy

Table Of Contents

  1. About us
  2. Our processing of your personal information
    • Prospective Clients
    • Existing Clients
    • Clients’ Family Members, Business Associates or Beneficiaries
    • Other Business Partners
    • User Of Our Website
  3. What marketing activities do we carry out?
  4. How long do we keep your personal information for?
  5. What is our approach to sending information overseas?
  6. Your rights
  7. Contacting us
  8. Updates to this Notice

 

  1. About us

In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information.  This makes us a “data controller”.

The Partner named on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.

  1. Our processing of your personal information

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.

We also use details of any unspent criminal convictions for fraud prevention purposes.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.

In order to make this notice as user friendly as possible, we have split it into different sections. Please refer to the section that best describes your relationship with us.

2.1    Prospective clients

This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.

What personal information may we collect?

What special categories of personal information may we collect?

How will we collect your personal information?

We will collect information directly from you when:

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information”:

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basiss in these circumstances:

Purpose for processing

Purpose for processing Lawful Basis for using your personal information Lawful Basis for using your  special categories of personal information

 

To verify your information. ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to verify your identity).

 

·       You have given us your explicit consent.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

·       We need to establish, exercise or defend legal rights.

To comply with our legal or regulatory obligations.

 

·       We need to use your information in order to comply with our legal obligations.

 

·       We need to use your information in order to establish, exercise or defend legal rights.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

To set you up as a client on client relationship management systems and to communicate with you in respect of your application and service preferences.

 

·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to establish you as a client).

 

·       You have given us your explicit consent.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

For business purposes and activities including maintaining business records, file keeping and strategic business planning. ·       We have a valid business reason (to run our business efficiently and effectively).

 

·       You have given us your explicit consent.

·       We need to use your information in order to establish, exercise or defend legal rights.

To provide marketing information where you have provided your consent.

 

 

·       You have given us your explicit consent.

 

·       Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent. ·       We have a valid business reason (to send you selected communications about other products and services we offer) ·       Not applicable
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys). ·       We have a valid business reason (to develop and improve the products and services we offer).

 

·       You have given us your explicit consent.

 

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

2.2    Existing clients

This section will apply if you currently receive wealth management services from us. This section will set out how we use your information.

What personal information may we collect?

What special categories of information will we collect?

How will we collect your personal information?

We will collect information directly from you when:

We will also collect your personal information from:

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information”:

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

Purpose for processing

Purpose for processing Lawful Basis for using your personal information Lawful Basis for using your  special categories of personal information

 

To carry out identification checks  and checks against sanction lists and politically exposed persons (PEP) screening

 

·       It is necessary to enter into your client agreement.

·       We have a valid business reason (to carry out necessary compliance checks).

·       We have a legal and regulatory obligation.

 

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

·       We need to establish, exercise or defend legal rights.

·       You have given us your explicit consent.

To verify your information throughout the course of our services. ·       It is necessary to enter into or perform your client agreement.

·       We have a legal and regulatory obligation.

·       We have a valid business reason (to verify your identity and to undertake client due diligence throughout the course of our relationship).

·       You have given us your explicit consent.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

·       We need to establish, exercise or defend legal rights.

To set you up as a client on the St. James’s Place client relationship management system and to communicate with you in respect of your service preferences. ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to establish you as a client).

 

·       You have given us your explicit consent.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

To provide services in accordance with your client agreement. ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).

·       You have given us your explicit consent.

·       We need to use your information in order to establish, exercise or defend legal rights.

To arrange and implement any of our recommendations e.g. investing into certain funds or arranging a product or insurance policy for you. ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).

·       You have given us your explicit consent.

·       We need to use your information in order to establish, exercise or defend legal rights.

To carry out annual reviews and reviews of ongoing suitability of your current arrangements ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to ensure that we are providing appropriate services according to your circumstances).

·       You have given us your explicit consent.

·       We need to use your information in order to establish, exercise or defend legal rights.

To prevent and investigate fraud. ·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to prevent and detect fraud and other financial crime).

 

·       We have a substantial public interest to prevent fraud

·       We need to use your information in order to establish, exercise or defend legal rights.

To comply with our legal or regulatory obligations.

 

·       We need to use your information in order to comply with our legal obligations.

 

·       We need to use your information in order to establish, exercise or defend legal rights.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

To communicate with you and resolve any complaints that you might have.

 

·       It is necessary to enter into or perform your client agreement.

·       We have a valid business reason (to communicate with you, record and investigate complaints and ensure that complaints are handled appropriately).

·       We need to use your information in order to comply with our legal and regulatory obligations.

 

·       We need to use your information in order to establish, exercise or defend legal rights.

 

To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys). ·       We have a valid business reason (to develop and improve the products and services we offer).

 

·       You have given us your explicit consent.

 

For business purposes and activities including maintaining business records, file keeping and strategic business planning. ·       We have a valid business reason (to run our business efficiently and effectively) ·       You have given us your explicit consent.

·       We need to use your information in order to establish, exercise or defend legal rights.

To apply for and claim on our own insurance.

 

·       We have a valid business reason (to maintain appropriate insurance) ·       We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.

 

 

·       You have given us your explicit consent.

 

·       Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent. ·       We have a valid business reason (to send you selected communications about other products and services we offer) ·       Not applicable


Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

2.3 Clients’ family members, business associates or beneficiaries

This section will apply if your personal information has been provided to us by a client to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or partner, dependant mentioned in a will or trust document, another beneficiary  a business partner) and will set out how we use your information.

What personal information may we collect?

What special categories of personal information may we collect?          

How will we collect your personal information?

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information”:

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

Purpose for processing

Purpose for processing Lawful Basis for using your personal information Lawful Basis for using your  special categories of personal information
To provide services to our clients ·       We have a valid business reason (to fulfil our contractual obligations to our clients and advise on the most appropriate investments for their personal circumstances) ·       You have given us your explicit consent and this has been provided to us by our client.

 

 

 

 

To prevent and investigate fraud. ·       We have a valid business reason (to prevent and detect fraud and other financial crime).

·       We need to use your information in order to comply with our legal obligations.

 

·       We have a substantial public interest to prevent fraud

·       We need to use your information in order to establish, exercise or defend legal rights.

To comply with our legal or regulatory obligations.

 

·       We need to use your information in order to comply with our legal obligations.

 

·       We need to use your information in order to establish, exercise or defend legal rights.

·       It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

For business purposes and activities including maintaining business records, file keeping and strategic business planning. ·       We have a valid business reason (to run our business efficiently and effectively) ·       You have given us your explicit consent and this has been provided to us by our client.

·       We need to use your information in order to establish, exercise or defend legal rights.

To provide marketing information where you have provided your consent.

 

 

·       You have given us your explicit consent.

 

·       Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent. ·       We have a valid business reason (to send you selected communications about other products and services we offer) ·       Not applicable

 

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

2.4 Other business partners

If you are a business partner such as a products provider, portfolio or fund manager or contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.

What personal information may we collect?

How will we collect your information?

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information”:

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

Purpose for processing

Purpose for processing Lawful Basis for using your personal information Lawful Basis for using your  special categories of personal information
To carry out fraud, credit and anti-money laundering checks on you

 

·       It is necessary to enter into a contract with you.

·       We have a valid business reason (to assess your suitability as a business partner).

·       We need to use your information in order to comply with our legal obligations.

 

Not applicable
To carry out due diligence on you. ·       We have a valid business reason (to ensure that you can provide guarantees in terms of confidentiality and security measures you implement to protect the information we are sharing with you about our clients). Not applicable
To comply with our legal or regulatory obligations.

 

·       We need to use your information in order to comply with our legal obligations, for example to pay your invoices for the services you have provided. Not applicable
For business purposes and activities including maintaining business records, file keeping and strategic business planning. ·       We have a valid business reason (to run our business efficiently and effectively) Not applicable
For compliance and monitoring purposes. ·       It is necessary to enter into a contract with you.

·       We have a valid business reason (to ensure we are compliant and carrying out appropriate monitoring activities).

Not applicable


Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:

2.5 Users of our website

If you use our website, this section will be relevant to you and sets out our uses of your personal information.

What personal information may we collect?

How will we collect your personal information?

We will collect your information directly from our website.

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

Purpose for processing

Purpose for processing Lawful Basis for using your personal information Lawful Basis for using your  special categories of personal information
To respond to any enquiries you have submitted. ·       We have a business reason (to respond to your enquiries). Not applicable

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to:

 

  1. What marketing activities do we carry out?

We carry out the following marketing activities depending on the relationship that we have with you:

Where you are a prospective client

We will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about our wealth management services that we offer which you might be interested in.

In these letters, we inform you that we will contact you via telephone to discuss our service offerings unless you notify us that you do not wish to receive such a call.

As part of our follow-up telephone call we will discuss the wealth management services we offer which you might be interested in and we will answer any questions that you may have.

Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you.

We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so.

We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this.

Where you are an existing client

We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so.

We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have consented to receive this.

General marketing practices

If you wish to opt out of marketing, you may do so by clicking on any “unsubscribe” link or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us using the details set out in section 7 to update your contact preferences.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.

  1. How long do we keep personal information for?

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to.

If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 7.

5.What is our approach to sending your personal information overseas

There are a small number of instances where your personal information is transferred to countries outside of the European Economic Area (“EEA“) such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.

Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:

 

Country of transfer Reason for the transfer Method we use to protect your information
Hong Kong, Singapore, Shanghai Provision of data to international offices to support clients living overseas. We have standard contractual clauses in place

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 7.

6.Your rights

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 7 if you wish to exercise these rights; we will not usually charge you.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

We will of course inform you if any of the above situations arise and if we are unable to comply with your request.

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

It would be helpful if could please complete the Data Subject Request Form, available from your partner,  to request a copy of the information we hold so that we can ensure we have all the relevant information we need to appropriately respond to your request.

Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.

In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.

Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.

You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.

You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time.  You can do this either by clicking on the “unsubscribe” button in any email that we send to you or by contacting us using the details set out in section 8.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.

In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request

We do not carry out any automated decision making to provide products and services to you.

If you believe that we have breached data protection laws when using your personal information, you have a right to complain to the Information Commissioner’s Office (ICO).

You can visit the ICO’s website at https://ico.org.uk/ for more information.  Please note that lodging a complaint will not affect any other legal rights or remedies that you have.

  1. Contacting us

If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our St. James’s Place Data Protection Officer at St. James’s Place plc, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom, dpo@sjp.co.uk and 01285718453.

  1. Updates to this notice

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up to date notice.

This notice was last updated on 25th May 2018.