Employee and Executive dealing - Share Plans

Employee and Executive dealing Share Plans - Privacy Policy

Equiniti Financial Services Limited (EFSL) Privacy Notice

 Equiniti Financial Services Limited handles a large amount of personal data in providing services to millions of UK customers. We are committed to keeping your data safe and using it in a clear and transparent way. This summary details why we hold your data, including any ways that you might not expect. Please read the following Privacy Notice pages if you want to know more.

We hold your data

We always seek to use your data in ways you would expect, but we also have to hold data to meet legal and regulatory requirements relating to the products you use.

You have rights over the data we hold about you.  In particular, you can choose if you want to receive information about offers, rewards and new products.  You can tell us how you would prefer to hear from us.  You are able to opt out at any time. 

Things you might not know

Equiniti Financial Services Limited (EFSL) Privacy Notice

 Updated Sept 14 2018

We understand how important your personal data is and are committed to protecting and respecting your privacy.

‘Personal Data’ means any information relating to or which identifies you.  This can include items such as your name, address, phone number, identification numbers (such as an account number or your national insurance number), location data or online identifiers.  Personal data can be held electronically or in certain paper records. 

The General Data Protection Regulation (GDPR) regulates the processing of personal data.  The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations handling personal data must adopt.  This Privacy Notice is issued in compliance with GDPR and seeks to explain:

  1. Who we are;
  2. Products and services covered by this Privacy Notice;
  3. How we collect your personal data;
  4. Why we collect your personal data;
  5. How long we hold the personal data ;
  6. The conditions under which we can share it with others;
  7. Overseas processing;
  8. How we keep your personal data secure;
  9. Your personal data rights and how to exercise them;
  10. Useful information; and
  11. Any further questions.

 

1.   Who we are

Equiniti Financial Services Limited (EFSL) is one company within the Equiniti Group, and is authorised and regulated by the Financial Conduct Authority.  Our main business is investment and general insurance services.  Our registered address is Aspect House, Spencer Road, Lancing, West Sussex, BN99 6DA and our ICO registration number is: Z1028420.

EFSL is a ‘Data Controller’.  This means that we are responsible for deciding how and why we hold and use personal data about you.

In this Privacy Notice, ‘we’, ‘us’ and ‘our’ will always mean EFSL, as Data Controller.  Selftrade is a trading name of EFSL.

If you have questions about your products and services please contact your relevant Customer Experience team:

Selftrade accounts and selftrade.co.uk

0345-070-0720

Shareview Investment Account / Equiniti ISA

0345 300 0430

Certificated dealing

0345-603-7037

Equiniti Corporate Dealing

0808 100 1045

Dividend Re-Investment Plans - DRIPs  

0371-384-2268

Corporate Sponsored Nominee

0371-384-2030

Global Nominee (Premier)

0345-600-8824

General enquiries

0345-607-6838

Textel/Minicom number

0371 384 2255

 

2.   Products and services covered by this Privacy Notice

 This notice applies to all of the following EFSL products, services, website and App:

3.   How we collect your personal data

The personal data we hold includes your name, postal address, email address and phone number, date of birth, financial information and for some accounts and transactions, additional information about you such as your National Insurance Number and Nationality to enable us to provide you with our products and services.  

We use many different kinds of personal data dependent upon the relationship you have with us and the products and services that you use. And we collect it through a variety of different ways:

Information you provide to us

Information we collect about you when you use our services

Information we receive from third parties

 

Special types of data - The law and other regulations treat some types of personal information as special. We will only collect and use this information if the law allows us to do so:

Keeping your personal data up to date

It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this.  Please help us by ensuring that you review the information held about you regularly and let us know as soon as anything needs updating or correcting.

Other people’s personal data

The information you give us in your application form or other related documents, or that we collect through your use of our services, may contain your or another person’s personal data.  If you provide us with information about another person, you confirm that they have appointed you to act for them, they consent to you providing their personal data to us and any processing of their personal data and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice.

 

4.   Why we collect your personal data

In the table below we demonstrate why and how we use your personal data as well as providing the legal reasons which we rely upon. 

Under Data Protection legislation we must always have a legal reason for processing your personal data.  One of the legal reasons is when we use your personal data for our legitimate interests, this is usually when we have a business reason, however, we must always ensure that we take your interests into consideration too, and ensure that the use is fairly balanced.  We tell you below when we rely on legitimate interests and what our legitimate interests are.

Why we use your personal data

How we use your personal data

Our legal reasons for using your personal data

Provision of Financial Services, including the administration and management of customer records

o   To manage and operate your account with us to facilitate the provision of products and services, this includes retaining records of your instructions and telephone calls and keeping your account records up to date.

o   To complete any transaction that you instruct us to undertake, and any legal obligations we have in relation to the transactions.  As part of account opening, we are legally obliged to confirm your identity before we can accept your application.

o   To provide you with transaction records / confirmation notices and statements as required by the service.

o   To respond to any complaints and / or data rights that you invoke.

o   To notify you about changes to our service and to send you service emails relating to your account.

o   Processing our fees, charges, and any interest due on your accounts.  Enforcing or obtaining settlement of debts owed to us or in relation to investments made on your behalf.

o   For certain types of accounts, we also define our customers to facilitate the calculation of fees.

o   To keep our websites and portals secure and permit you safe access to our services.

  • As part of contract preparations and obligations between us and you.
  • With your consent.
  • To comply with legal requirements placed upon us, such as the Financial Conduct Authority and Financial Crime regulations.
  • Our legitimate interests, such as the proper administration of our service and business, for example:
    • Keeping our records up to date.
    •  Defining types of customers for new products and services.
    • Seeking your consent when we need it to contact you.
    • Operating efficiently.
    • Enabling and monitoring your use of our website and services.
    • To meet our regulatory requirements
    •  To identify when you are no longer able to use the product or service in accordance with the terms and conditions; or to restrict your account to meet product restrictions

Prize draws, offers, marketing of our products and services

o   To allow you to participate in interactive features of our service, when you choose to do so.

o   Identifying if any of our products or services may be of interest to you and making suggestions and recommendations to you about them. 

o   To provide you with the information, products and services that you request from us via your chosen channel.

o   To administer any prize draws that you are offered and elect to enter as an incentive to operate your account, for example as part of electing to receive dividends by BACS rather than by cheque.

o   To ask you if you wish to hear from other entities within the Equiniti Group of Companies that offer complimentary financial services such as foreign exchange services.

o  To share only on request the full name & county of any prize draw winners.

o   We can ask you from time to time to confirm or update your choices, such as when there is a change in the law or the structure of our business.

 

IMPORTANT

You can withdraw from EFSL marketing and / or prize draw offers at any time.  Please contact us if you wish to update your preferences.

 

EXCEPTIONS

In limited circumstances, and dependent upon the account that you hold, you many receive marketing communications from the company which you hold shares in.  This marketing will be clearly marked as issued by the company, however, another part of the Equiniti group of companies may assist in the delivery of those messages.  In these instances you will need to opt out of marketing with the company concerned using the details contained within the message as they are not EFSL marketing messages.

o   With your consent.

o   When we have collected your personal data when applying for, or enquiring about, a product or service, provided you could “opt-out” of receiving marketing communications at the time we collected your personal data and have been advised on how to easily do this in our subsequent communications with you for example using an ‘unsubscribe’ button at the bottom of emails.

o   Our legitimate interests, namely - the proper administration of our service and business for example:

·         Keeping our records up to date.

·         Defining types of customers for new products and services.

·         Seeking your consent when we need it to contact you.

·         Operating efficiently.

·         Enabling and monitoring your use of our website and services.

 

IMPORTANT

Please also refer to the exceptions noted in the marketing section of this Privacy Notice.

 

Profiling

Understanding our customers: We can place you into groups of customers with similar interests, account patterns and preferences.  These are called customer segments.  We can also use a customer insight technique which analyses past observations to predict future behaviour.  This is called propensity modelling.  These activities are used to predict how we can best deliver our service to you as well as tailor our product or service offerings and contact you efficiently and effectively with information that is relevant to you.  

 

You can ask us to stop profiling at any time – see section 9 - Your Rights.

o   Our legitimate interests, such as the proper administration of our service and business, for example:

·         Keeping our records up to date.

·         Defining types of customers for new products and services.

·         Seeking your consent when we need it to contact you.

·         Operating efficiently.

·         Enabling and monitoring your use of our website and services.

·         To meet our regulatory requirements.

Automated decision making

 

 

 

We use personal data to help us make automated decisions based on the personal data that we hold about you, or are permitted to collect from others.  Common examples of when we do this are noted below:

o   Account Opening: We are required to check that you meet the requirements of the account you have selected, to do this we can use, and validate, personal data about you such as your age, residency, nationality and financial position.

o   Account Pricing: We can analyse the transactions you have undertaken in a predetermined period to calculate what we charge for some products and services.

o   Credit checks: We use credit reference agencies for account purposes including confirming your identity or implementing trading limits.  The decisions we make are based on the information you have supplied, that we already hold and from the credit reference agencies who separately hold information about you, or from policy decisions taken by Banks, card and payment processing centres.  This includes rejecting trades if they fall outside of your agreed trading limit. To resolve any issues arising you may have to speak to these agencies directly.

 

You can ask to have one of our staff to review any automated decision about you at any time – see section 9 - Your Rights.

o   As part of contract preparations and obligations between us and you.

o   With your consent.

o   To comply with legal requirements placed upon us, such as the Financial Conduct Authority and Financial Crime regulations.

o   Our legitimate interests, such as the proper administration of our service and business, for example:

·         Keeping our records up to date.

·         Defining types of customers for new products and services.

·         Seeking your consent when we need it to contact you.

·         Operating efficiently.

·         Enabling and monitoring your use of our website and services.

·         To meet our regulatory requirements.

 

Assessment and collection of taxes

To deduct the relevant tax and duties (such as stamp duty, dividend tax and income tax) and submit returns to the relevant regulatory authorities.

 

For some products, this is achieved through our liaison with your employer.

o  As part of contract preparations and obligations between us and you.

o  With your consent.

o  To comply with legal requirements placed upon us, such as the Financial Conduct Authority.

o  To meet our regulatory requirements.

Financial crime

Financial crime and money laundering:  We analyse your personal data for financial crime, money laundering and fraud risk purposes in accordance with UK and EEA regulations which are placed upon us.  This can include:

o   Confirming your identity (through the use of Credit Reference agencies – see above).

o   Verifying your bank details.

o   Using fraud prevention agencies. We study and learn about how you use our products and services and use this information to better detect fraud or unusual activities.  We do this with fraud prevention agencies.

o   Analysing our databases, investigating, detecting and report financial crimes as well as taking measures to prevent financial crime.

o   Developing and improving our financial crime controls.

o   Managing financial risks both to us and to you.

o   As part of contract preparations and obligations between us and you.

o   With your consent.

o   To comply with legal requirements placed upon us, such as the Financial Conduct Authority and Financial Crime regulations.

o   Our legitimate interests, such as the proper administration of our service and business, for example:

·         Keeping our records up to date.

·         Operating efficiently.

·         Enabling and monitoring your use of our website and services.

·         To meet our regulatory requirements.

Improving our products and services

 

o   To identify service improvements such as when troubleshooting, undertaking data analysis, testing new products, using your personal data for research, statistical and survey purposes.

o   To ensure that content from our websites are presented in the most effective manner for you and for your device.

o   To develop and manage our products, brands and services and to calculate how we should structure any fees and charges.

o   How we manage and work with other companies in the delivery of your products and services.

o   To study how you and our other customers use our products and services.

o   To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which can be based on your activity on our website(s) or the website of another Equiniti Company or third parties’ websites.  We can do this ourselves or appoint an agency to do this on our behalf.

o   As part of contract preparations and obligations between us and you.

o   With your consent.

o   To comply with legal requirements placed upon us, such as the Financial Conduct Authority and Financial Crime regulations.

o   To meet our regulatory requirements

o   Our legitimate interests, such as the proper administration of our service and business, for example:

·         Keeping our records up to date.

·         Defining types of customers for new products and services.

·         Seeking your consent when we need it to contact you.

·         Operating efficiently.

·         Enabling and monitoring your use of our website and services.

 

Some of this information will be gathered by cookies that you have consented can access your computer. Please refer to the cookie policies on the individual websites you visit for more information;

 

If you choose not to give personal information

We need to collect personal information required by law or under the terms of a contract we have with you.  If you choose not to give us the personal data we need it can mean that we have to cancel or decline a product or service that you request or have with us.  So that you know what information is optional, we make it clear at the time we collect your personal data.

 

5.   How long we hold your personal data

Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data.  We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.

The provision of these products and services are subject to legal and regulatory retention periods. These vary between products, and the type of data involved. Within this framework the maximum time we will retain any of your personal data will be the duration of the contract and for a period of up to 12 years following the completion of the contract, for the reasons noted below:

We can keep your data for longer than 12 years if we cannot delete it for legal, regulatory or technical reasons. We can also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

For full details of our retention policies, please contact us.

 

6.   The conditions under which we can share your personal data with others

The information we hold about you is confidential and we will only share your personal information to enable us to deliver the product(s) or service(s), examples are as follows:

We will only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this policy.  Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.

We are also required to share your personal data with external third parties as follows (but not limited to):

 

7.   Overseas Processing

 Personal data will be shared with members of the Equiniti Group outside of the European Economic Area (EEA) and the European Union (EU), including Equiniti India Private Limited which is based in India, for the purposes described in this Privacy Notice. For these transfers we utilise Model Clauses recognised by the European Commission.

When we contact you via email, one of our service providers uses services outside of the EEA and EU. For these transfers, we utilise Model Clauses recognised by the European Commission.

If you would like to obtain a copy of the Model Clauses we use to share personal information within the Equiniti Group or our email service provider, please contact our Data Protection Officer using the details provided in this Privacy Notice.

Please note that information protection laws do vary from country to country.  In particular, the law of the country in which you are resident or domiciled may offer a higher standard of protection than the laws in the United Kingdom and / or those other countries in which we store and use the personal data we collect.  Our transfer of personal data to other countries could result in that personal data being available to governments and other authorities in those countries under their laws.

By using our Service, you agree to this international transfer, storing and processing.

8.   How we keep your personal data secure

 We understand how important your personal data is to you and we take appropriate steps to ensure that it remains secure.

We safeguard your personal data across all our computer systems, networks, websites, and offices as much as possible through appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) and our Information Security policies are aligned to ISO27001, which is an internationally recognised security standard.

We also use secure ways of communicating with you such as when collecting your personal data or providing your account information:

Where we have given you (or where you have chosen) a password or unique identifier (PIN) which enables you to access certain parts of our websites, you are responsible for keeping this password / PIN confidential, along with any username. We will never ask for your full password or PIN, and you must not divulge your full password to us or anyone else.  We recommend that any password or PIN you set is not easily guessable, and changed frequently (at least once a month).

Because we cannot guarantee the confidentiality of personal data sent on the internet you should never send your login details via email.

Security concerns

If you ever receive a communication from us by post, email or by phone that you are concerned it is not genuine, please contact us using the contact details in section 1.

You must immediately inform us if you become aware, or suspect, that someone else has knowledge of your account details.

If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of Get Safe Online, which can be accessed at www.getsafeonline.org.

 

9.   Your personal data rights and how to exercise them

 You have rights in respect of the personal data that we hold about you.  They include the right to request a copy of the information that we hold about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time.  Details about all of your rights are provided below.

Some of these rights are conditional and depend upon why we are processing your personal data.  This means that we cannot always be able to respond to your request in the way that you want.  For example:

Your rights

 

Explanatory detail

The right to be informed about how we use your personal data.

This Privacy Notice provides you with the details on how we use and process your data.

The right of access to a copy of any personal data EFSL processes about you, together with certain additional information.

If you request to see your personal data, your initial request will be free of charge; subsequent requests may attract an administration fee. The additional information includes details of the categories and recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

The right to request us to rectify or update it.

This will be relevant where the personal data we hold is or has become inaccurate or incomplete, taking into account the purposes of the processing. Please explain why you consider the data inaccurate or incomplete.

The right to request us to erase your personal data in certain circumstances.

 

 

The circumstances when erasure can apply include when we no longer need it to meet a lawful basis for processing unless that basis is consent and you withdraw your consent or you object to the processing or the processing is unlawful.

However, certain exclusions apply - where the processing is necessary for compliance with a legal obligation or to establish, exercise or defend legal claims.

The right to request us to restrict processing it.

This request can be used to stop us processing your personal data: if you disagree over the accuracy of the personal data until we have verified the data; the reason for processing; or if you wish us to retain your personal data for longer than our retention period, e.g. to establish, exercise or defend a legal claim.

The right to request a copy of your information for data portability purposes.

If you have provided personal data to us under contract or because you consented to the processing and use the data by automated means, then you have the right to instruct us to transmit that personal data to you or another data controller in a machine-readable format.

The right to object to us processing your personal data.

You have a right to object to us processing your data where we are processing it for the purpose of legitimate interests.

You can also object to direct marketing communications from us about products, offers, competitions, or services and any profiling that we can perform in relation to direct marketing.  You can do this at the point of data collection, through the use of any opt-out functionality on text and emails, via your preference centre or by contacting the helpline service.

You can update your marketing preferences at any time through the use of the opt-out functionality.

You have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing before the withdrawal.

If you would like to receive the marketing described above, please ensure you have indicated your preferences accordingly.

Rights related to decisions based solely on automated processing.

Where this processing produces legal effects or significantly affects you, you can object to this processing unless the processing is necessary as part of our contract, or is required by legislation.

Right to lodge a complaint with a supervisory authority.

If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection team who will investigate the matter and report back to you.

If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country.  In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation. They can be contacted by email: casework@ico.org.uk; post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; or by telephone: 0303 123 1113.

 

10. Useful information

10.1 - Children (16 years and under) and Vulnerable Adults

We are committed to the privacy protection of children and vulnerable adults. If you are aged 16 or under‚ and we need to process your personal data you must obtain the permission of your parent/guardian before you share your personal data with us.  If we are notified that you are a vulnerable adult we will liaise with your authorised representative, once we are in receipt of the appropriate permissions.

10.2 - Use of ‘cookies’

Cookies are text files placed on your computer to track visitor use of the website and to compile statistical reports on website activity. This helps us to improve our website and deliver a better more personalised service.

You can switch off cookies by setting your browser preferences. However, turning cookies off will result in a loss of functionality when using our website. For more information on how to switch off cookies on your computer, please see the relevant cookie policy for the website you are using. These are typically found in the footer links at the bottom of the page.

10.3 - Links to other websites

Our websites contain links to other websites run by other organisations, or other Equiniti companies. This Privacy Notice applies only to EFSL websites, where the link appears.  When you are on another website, we encourage you to read their privacy statements as it will take precedence over this Privacy Notice.

We are not responsible for the privacy policies and practices of other sites.

10.4 - Social media, blogs, reviews, and similar services

Any social media posts or comments you make to us (e.g. on our own Facebook page) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they are made and could be made public by that platform. These platforms are controlled by other organisations, and so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you are unhappy about it.

Any blog, review or other posts or comments you make about us, our products and Services on any of our blog, review or user community services will be shared with all other members of that service and the public at large.

You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.

10.5 Changes to this policy

We review our use of your personal data regularly.  In doing so, we can change what personal data we collect, how we keep it and what we do with it.  As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.

We will endeavour to alert you to these changes so that you can check you are happy with it before proceeding any further.  Please look out for notices from us alerting you to these changes, via our websites or other timely communications.  If you use our website and see such an alert, please take a moment to ensure that you’re happy with any changes.

By continuing to use our products and services, you will be bound by this Privacy Notice.

However, we will also tell you of the changes where required by law to do so.

This policy was issued 24 May 2018.   If you require copies of previous versions of the EFSL Privacy Notices, please contact the Data Protection Officer using the contact details noted below.

 

11. Any further questions about this Privacy Notice

We hope that this Privacy Notice has been helpful in setting out how we handle your personal data and your rights to control it.  If you have any questions that remain unanswered, please visit our Customer Privacy Centre or contact our Data Protection Officer:

Read our other privacy policies

Still have questions?

Explore answers to our most frequent questions...